Assets
| Type | Time | Amount | Unit |
|---|---|---|---|
| ifrs-full:Assets | 2024-12-31 | 465795000000 | dkk |
| ifrs-full:Assets | 2023-12-31 | 314486000000 | dkk |
Revenue
| Type | Start date | End date | Amount | Unit |
|---|---|---|---|---|
| ifrs-full:Revenue | 2024-01-01 | 2024-12-31 | 290403000000 | dkk |
| ifrs-full:Revenue | 2023-01-01 | 2023-12-31 | 232261000000 | dkk |
| ifrs-full:Revenue | 2022-01-01 | 2022-12-31 | 176954000000 | dkk |
XML
See the xml submitted here:
XML: INVALID
Separator
The full data:
<?xml version="1.0" encoding="UTF-8" standalone="no"?>
<xbrli:xbrl xmlns:xbrli="http://www.xbrl.org/2003/instance"
xmlns="http://www.w3.org/1999/xhtml"
xmlns:arr="http://xbrl.dcca.dk/arr"
xmlns:ixt="http://www.xbrl.org/inlineXBRL/transformation/2020-02-12"
xmlns:cmn="http://xbrl.dcca.dk/cmn"
xmlns:sob="http://xbrl.dcca.dk/sob"
xmlns:link="http://www.xbrl.org/2003/linkbase"
xmlns:ifrs-full="https://xbrl.ifrs.org/taxonomy/2022-03-24/ifrs-full"
xmlns:iso4217="http://www.xbrl.org/2003/iso4217"
xmlns:ix="http://www.xbrl.org/2013/inlineXBRL"
xmlns:mrv="http://xbrl.dcca.dk/mrv"
xmlns:NOV="http://xbrl.novonordisk.com/2024-12-31"
xmlns:fsa="http://xbrl.dcca.dk/fsa"
xmlns:xbrldi="http://xbrl.org/2006/xbrldi"
xmlns:gsd="http://xbrl.dcca.dk/gsd"
xmlns:xlink="http://www.w3.org/1999/xlink"
id="DKGAAP"
xml:lang="en">
<link:schemaRef xlink:href="http://archprod.service.eogs.dk/taxonomy/20241001/entryDanishGAAPExcludingBalanceSheetIncomeStatementIncludingManagementsReview20241001.xsd"
xlink:type="simple"/>
<xbrli:context id="ctx-1">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-55">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2023-01-01</xbrli:startDate>
<xbrli:endDate>2023-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-37">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfExecutiveBoardDimension">
<cmn:memberOfBoardIdentifier>1</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-38">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfExecutiveBoardDimension">
<cmn:memberOfBoardIdentifier>2</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-39">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>1</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-40">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>2</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-41">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>3</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-42">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>4</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-43">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>5</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-44">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>6</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-45">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>7</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-46">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>8</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-47">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>9</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-48">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>10</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-49">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>11</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-50">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfMemberOfSupervisoryBoardDimension">
<cmn:memberOfBoardIdentifier>12</cmn:memberOfBoardIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-52">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfAuditorDimension">
<cmn:auditorIdentifier>2</cmn:auditorIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-51">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfAuditorDimension">
<cmn:auditorIdentifier>1</cmn:auditorIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-54">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfSubstainabilityAuditorDimension">
<cmn:sustainabilityAuditorIdentifier>2</cmn:sustainabilityAuditorIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:context id="ctx-53">
<xbrli:entity>
<xbrli:identifier scheme="http://standards.iso.org/iso/17442">549300DAQ1CVT6CXN342</xbrli:identifier>
</xbrli:entity>
<xbrli:period>
<xbrli:startDate>2024-01-01</xbrli:startDate>
<xbrli:endDate>2024-12-31</xbrli:endDate>
</xbrli:period>
<xbrli:scenario>
<xbrldi:explicitMember dimension="cmn:ConsolidatedSoloDimension">cmn:ConsolidatedMember</xbrldi:explicitMember>
<xbrldi:typedMember dimension="cmn:IdentificationOfSubstainabilityAuditorDimension">
<cmn:sustainabilityAuditorIdentifier>1</cmn:sustainabilityAuditorIdentifier>
</xbrldi:typedMember>
</xbrli:scenario>
</xbrli:context>
<xbrli:unit id="pure">
<xbrli:measure>xbrli:pure</xbrli:measure>
</xbrli:unit>
<gsd:NameOfSubmittingEnterprise contextRef="ctx-1" id="s10__8__16" xml:lang="en">Novo Nordisk A/S</gsd:NameOfSubmittingEnterprise>
<gsd:NameOfReportingEntity contextRef="ctx-1" id="s10__8__10" xml:lang="en">Novo Nordisk A/S</gsd:NameOfReportingEntity>
<gsd:AddressOfSubmittingEnterpriseStreetAndNumber contextRef="ctx-1" id="s10__8__17" xml:lang="en">Novo Alle 1</gsd:AddressOfSubmittingEnterpriseStreetAndNumber>
<gsd:AddressOfReportingEntityStreetName contextRef="ctx-1" id="s10__8__11" xml:lang="en">Novo Alle</gsd:AddressOfReportingEntityStreetName>
<gsd:AddressOfReportingEntityStreetBuildingIdentifier contextRef="ctx-1" id="s10__8__12" xml:lang="en">1</gsd:AddressOfReportingEntityStreetBuildingIdentifier>
<gsd:AddressOfSubmittingEnterprisePostcodeAndTown contextRef="ctx-1" id="s10__8__18" xml:lang="en">2880 Bagsværd</gsd:AddressOfSubmittingEnterprisePostcodeAndTown>
<gsd:AddressOfReportingEntityPostCodeIdentifier contextRef="ctx-1" id="s10__8__13" xml:lang="en">2880</gsd:AddressOfReportingEntityPostCodeIdentifier>
<gsd:AddressOfReportingEntityDistrictName contextRef="ctx-1" id="s10__8__14" xml:lang="en">Bagsværd</gsd:AddressOfReportingEntityDistrictName>
<gsd:IdentificationNumberCvrOfReportingEntity contextRef="ctx-1" id="s10__8__15">24256790</gsd:IdentificationNumberCvrOfReportingEntity>
<gsd:IdentificationNumberCvrOfSubmittingEnterprise contextRef="ctx-1" id="s10__8__19">24256790</gsd:IdentificationNumberCvrOfSubmittingEnterprise>
<mrv:LinkToCorporateGovernanceReport contextRef="ctx-1" id="s10__8__30">www.novonordisk.com/about/corporate-governance.html</mrv:LinkToCorporateGovernanceReport>
<mrv:CorporateGovernanceReport contextRef="ctx-1" id="s10__8__29" xml:lang="en">Corporate governanceGovernance structureThe shareholders of Novo Nordisk exercise their rights at the Annual General Meeting, which is the supreme governing body of the company. The general meeting, inter alia, adopts the companyâs Articles of Association, approves the Annual Report and elects the Board of Directors. Any shareholder has the right to raise questions at general meetings. Resolutions can generally be passed by a simple majority. However, resolutions to amend the Articles of Association require two-thirds of the votes cast and capital represented, unless other adoption requirements are imposed by the Danish Companies Act. Novo Nordisk has a two-tier management structure consisting of the Board of Directors and Executive Management. The governance structure and rules of Novo Nordisk are further described in our Articles of Association and our Corporate Governance Report, both available at: www.novonordisk.com/about/corporate-governance.html.Foundation ownershipNovo Holdings A/S, a Danish company wholly owned by the Novo Nordisk Foundation, holds the majority of votes at Novo Nordisk A/Sâ general meetings. The combination of foundation ownership and stock listing enables Novo Nordisk to embark on long-term sustainable strategies while maintaining short-term transparency on performance. Our foundation ownership supports the overarching imperative to be both commercially successful and responsive to the wider needs of society. The Novo Nordisk Foundation has two objectives: to provide a stable basis for the commercial and research activities of Novo Nordisk, Novonesis and additional companies in Novo Holdingsâ investment portfolio; and to support scientific, humanitarian and social causes. Please refer to the section on value creation on page 9. For more information about the ownership structure of Novo Nordisk, see page 36.Corporate governance reportingNovo Nordisk reports in accordance with the Danish Corporate Governance Recommendations, which are implemented by Nasdaq Copenhagen in the Nordic Main Market Rulebook for Issuer of Shares, as well as the Corporate Governance Standards of the New York Stock Exchange applicable to foreign private issuers. Novo Nordisk complies with the Danish Corporate Governance Recommendations as we account for which recommendations we comply with or deviate from and explain our chosen approach. You can find further information about our corporate governance practices and statement on our approach to each of the Danish Corporate Governance Recommendations as well as the Corporate Governance Standards of the New York Stock Exchange in our Corporate Governance Report, available at: www.novonordisk.com/about/corporate-governance.html.RemunerationExecutive remuneration is linked to financial performance as well as non-financial performance (e.g. innovation and sustainability). Novo Nordisk has prepared a separate Remuneration Report describing the remuneration awarded or due during 2024 to the Board of Directors and Executive Management members registered with the Danish Business Authority. The Remuneration Report is submitted to the Annual General Meeting for an advisory vote. The Remuneration Policy and the Remuneration Report are available at: www.novonordisk.com/about/corporate-governance.html.Disclosure regarding change of control provisionsIt is disclosed that Novo Nordisk does not have any material contracts that take effect, alter or terminate upon a change of control of Novo Nordisk following implementation of a takeover bid. In the event of termination â whether by Novo Nordisk or by the individual â due to a merger, acquisition or takeover of Novo Nordisk, members of Executive Management registered with the Danish Business Authority are, in addition to the notice period, entitled to a severance payment of 24 monthsâ base salary plus pension contribution.Ethics and complianceIn Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme. Data privacy is a key component in our ethical principles, ensuring guardrails are in place to manage and mitigate risks, thus safeguarding our patients and society at large. We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities. You can read more about these principles, in accordance with the Danish Financial Statements Act Section 99d, at: www.novonordisk.com/data-privacy-and-user-rights/data-ethics.html.</mrv:CorporateGovernanceReport>
<mrv:SustainabilityReport contextRef="ctx-1" id="s10__8__31" xml:lang="en">SUSTAINABILITYSTATEMENT1. General information1.1 ESG performance Novo Nordisk strives to conduct its activities in a financially, environmentally, and socially responsible way. The year 2024 marks an important milestone for Novo Nordiskâs sustainability reporting. This is our first Sustainability statement prepared in accordance with the EU Corporate Sustainability Reporting Directive (CSRD). Through our disclosures, we endeavour to ensure transparency across all sustainability matters deemed material to Novo Nordisk, including the ways in which we impact people and society as a pharmaceutical company, both positively and negatively.The Sustainability statement covers our essential sustainability topics, aligned with our strategic aspirations as highlighted in the Annual review, which are the sustainability topics found to be material from both an impact and financial perspective. The statement also covers other important sustainability topics, deemed material due to our commitment to being transparent regarding our impacts. The Sustainability statement includes information on relevant processes, policies, actions, performance metrics and targets in accordance with the requirements of the European Sustainability Reporting Standards (ESRS) for each sustainability topic.In this first CSRD implementation year, we have focused on ensuring a concise Sustainability statement, in line with our financial reporting. In addition, we have strived to translate the sector-agnostic CSRD requirements into relevant information to Novo Nordisk. In particular, we have ensured that the standard for consumers and end-users reflects our reality of serving patients. We remain committed to continuing to improve the standardisation and transparency of sustainability information, while also doing our part to ensure our sustainability reporting is relevant and clear to all stakeholders. In parallel to implementing thenew reporting requirements, we have accelerated on our strategic ambitions to further progress on sustainability in 2024. To help serve people living with serious chronic diseases, we reached a total number of 45.2 million people with Diabetes and Obesity care treatment in 2024 (41.6 million in 2023). The growth in demand has resulted in further investments to expand capacity to be able to serve many more patients in the future. "To help serve people living with serious chronic diseases, we reached a total number of 45.2 million people with Diabetes and Obesity care treatment in 2024." We acknowledge that, as we continue to reach more patients, our social responsibility to improve access and affordability for vulnerable populations also grows. The number of vulnerable patients reached with our Diabetes products was 8.4 million, a decrease of 5% compared to 2023 due to reduced reach with human insulin tender sales. We remain committed to our broader access and affordability efforts to help address global health inequities while adhering to high quality standards. In regards to our target on reaching more children through our ® Changing Diabetesprogramme, we have reached 64,743 children since its start in 2009, which is in line with our target of reaching 100,000 children by 2030.Our prevention initiatives continue to be core to our social responsibility, and we broadened their scope with the relaunch of Cities for Better Health and our new Childhood Obesity Prevention Initiative, focusing on childhood overweight and obesity in underprivileged urban communities.In 2024, we strengthened our Circular for Zero ambition by setting a target, aligned with climate science, of a 33% reduction of our absolute scope 3 1emissions by 2033 compared to a 2024 baseline. In addition, we have a scope 1 and 2 emissions target of zero CO2e by 2030 and overall net zero emissions by 2045. Due to our rapid growth, in 2024 scope 1 and 2 emissions increased by 9% and scope 3 emissions by 24%, underlining the importance of our updated decarbonisation roadmap to decouple emissions from future growth.In 2024, we also set a global target to reduce our plastic footprint per patient by 30% by 2033. This will be achieved through circular product design, innovating treatment methods and efforts to convert to reusable devices. Furthermore, we developed a new nature roadmap with the overarching ambition of halting the loss of nature in our value chain by 2033 and becoming nature positive by 2045. To remain respected as a sustainable employer, we maintain a focus on diversity and inclusion and continue to work towards a balanced gender representation across all managerial levels globally. In 2024, we reached 42% female representation in senior leadership positions, and we are aiming for a minimum of 45% women and 45% men in senior leadership positions by the end of 2025.To improve safety, physical and mental wellbeing of our workforce, we monitorshort-term targets to reduce the number of accidents, as well as number of employees experiencing physical pain and symptoms of stress. In 2024, our year-on-year reduction targets were not met, due to different factors including the scaling of our organisation. A number of actions have been initiated in 2024 as we remain committed to protecting the health, safety and wellbeing of our workforce.The table below shows selected targets related to our strategic priorities, with key performance metrics disclosed on the following page. A complete list of all metrics is placed under relevant topical chapters.Strategic aspiration ESG metric Unit Target Base year Target year® Being respected for adding value to society Children reached via Changing Diabetesin Children Number 100,000 2009 2030Scope 1 and 2 (market-based) GHG emissions1,000 tonnes CO0 â 20302eScope 3 GHG emissions%(33%) 2024 2033Progress towards zero environmental impactTotal GHG emissions (net zero)1,000 tonnes CO0 â 20452ePlastic footprint per patient % (30%) 2024 2033Being respected as a sustainable employer Gender in senior leadership positions % men:women min. 45% â 20251. The target covers nearly 70% of our scope 3 emissions in accordance with SBTi provisions. Read more on page 57. Key ESG performance metrics for the year ended 31 DecemberAs a result of our double materiality assessment (see section 1.5 'Double materiality assessment' on page 52), we identifiedfour essential sustainability topics with both financial and impact materiality which are closely aligned with our strategic sustainability aspirations described in the Annual review: patient protection and quality of life, climate change, resource Essential sustainability topics Unit Table 2024 2023 2022 S4 Patient protection and quality of lifePatients reached with Diabetes and Obesity care products Number in millions 3.1.1 45.2 41.6 36.92Vulnerable patients reached with Diabetes care productsNumber in millions 3.1.1 8.4 8.8 - ®Children reached through the Changing Diabetes in Number 3.1.2 64,743 52,249 41,033Children programme (cumulative)Product recalls Number 3.1.4 3 2 3 Failed inspections Number 3.1.4 0 0 0E1 Climate changeScope 1 GHG emissions 1,000 tonnes CO2e 2.1.1 85 78 76 Scope 2 GHG emissions (market-based) 1,000 tonnes CO2e 2.1.1 16 15 163Scope 3 GHG emissions1,000 tonnes CO2e 2.1.1 2,160 1,743 -E5 Resource use and circular economyPlastic footprint (absolute) Tonnes 2.2.2 15,654 - -Plastic footprint per patient kg/patient 2.2.2 0.35 - -S1 Own workforce4Employees (headcount)Number 3.2.3 74,156 64,319 55,185Gender in senior leadership positions % men:women 3.2.7 58:42 59:41 61:395 Accidents per million Rate of recordable work-related accidents for own workforce3.2.6 1.2 1.3 1.3hours workedEmployees reporting symptoms of stress % 3.2.6 13.8 13.8 13.8Employees reporting symptoms of work-related physical pain % 3.2.6 6.8 7.1 7.82. 2023 figure has been restated. For more information, please see section 3.1 'Patient protection and quality of life' on page 75. 3. 2023 figure has been restated. For more information, please see section 2.1 'Climate change' on page 58. 4. Total headcount of 77,349 cf. note 2.4 in the Consolidated financial statements. The variance of 3,193 employees is due to Catalent employees not being included.5. 2023 and 2022 figures have been restated. For more information, please see section 3.2 'Own workforce' on page 84. 6. 2023 and 2022 figures have been restated. For more information, please see section 4.1 'Business conduct' on page 92.use and circular economy, and own workforce. Other important sustainability topics have been identified, which are only impact material. Listed below are selected performance metrics for both essential and important sustainability topics.Important sustainability topics Unit Table 2024 2023 2022G1 Business conductSubstantiated cases reported within accounting issues, fraud 6Number 4.1.4 242 221 227and business ethics matters via the Compliance HotlineAnimals purchased for research Number 4.1.8 49,284 56,508 79,750E3 Water3Total water consumption 1,000 m2.4.1 630 - -E2 PollutionTotal amount of substances of very high concern that leave facilities Tonnes 2.3.1 1 - -Total amount of substances of concern that leave facilities Tonnes 2.3.1 10 - -Performance of ESG ratings and rankingsNovo Nordisk aims to adhere to relevant reporting standards and guidelines. Our performance and management of sustainability practices continue to be recognised by various global ESG rating agencies, and we support engagement on an ongoing basis.Novo Nordisk welcomes the global call for ESG data standardisation to address the variance in rating methodologies, as well as the new EU regulation on ESG rating activities, fostering increased transparency of rating methodology and 7outcomes. Listed below are some of our latest recognitions from ESG rating agencies received in 2024.CDPMorningstar MSCI ESG ratingsCorporate KnightsAccess to Medicine SustainalyticsGlobal 100Index Released 6 Feb 2025823.2AAA6212From A to D onRisk rating from On a scale of Among the 100 most Out of 20 largest Climate and Water0 to >40AAA-CCCsustainable companiespharma companies7. Disclaimer statements to the use of logos can be found at: www.novonordisk.com/investors/esg.html.8. The general release of the 2024 CDP scores to all companies is planned for 6 February 2025. Novo Nordiskâs 2024 CDP scores will be available at: www.novonordisk.com/investors/esg.html.1.2 Basis for preparation of the Sustainability statementGeneral reporting standards and principlesOur Sustainability statement has been prepared in accordance with the ESRS as required by the Danish Financial Statement Act. Information derived from other EU legislations is listed in section 5, table 1.Certain disclosures have been prepared taking other sustainability reporting standards and guidelines into account, such as the Greenhouse Gas (GHG) Protocol, Science Based Targets initiative (SBTi), Science Based Targets Network (SBTN), Taskforce on Climate-related Financial Disclosures (TCFD), the Global Reporting Initiative Standards and the Danish Financial Statements Actâs sections 99d and 107d (see pages 16 and 85-87). The International Sustainability Standards Board (ISSB) recently issued IFRS S1 and IFRS S2, making them effective, but voluntary, for annual reporting beginning on or after 1 January 2024. While we are not required to follow these standards and have not adopted the rules, we took them into account during the preparation of the Sustainability statement.The time horizons considered for the preparation of the Sustainability statementare in line with those advised by the CSRD, and specifically up to one year as short-term, from one to five years as medium-term and more than five years for long-term.We have not opted to omit information corresponding to intellectual property, know-how, results of innovation, impending developments or matters in the course of negotiation, but in this first year of preparation of the Sustainability statement we opted to use the phase-in provisions listed in ESRS 1 Appendix C applicable to Novo Nordisk. Similarly, all voluntary disclosures that we consider required for a fair representation have been included. Table 2 in section 5 includes an index of all the ESRS requirements we comply with.Scope of consolidationThe organisational boundaries applied to Novo Nordiskâs consolidated Environmental, Social, and Governance (ESG) reporting align with those of the Consolidated financial statements. For disclosures on GHG emissions and pollution, we considered operational control when determining the consolidation scope. For policies, actions and targets related to 'Own workforce', NNE is excluded, as the subsidiary has its own processes in place.On 18 December 2024, Novo Nordisk acquired three fill-finish sites located in the US, Belgium and Italy from Novo Holdings, upon completion of its acquisition of Catalent Inc., a global contract development and manufacturing organisation. The impact of the acquisition has been deemed immaterial for sustainability reporting and is not included in our Sustainability statement, including the additional headcount, explaining the difference with Annual review and Consolidated financial statements.The Sustainability statement addresses the material impacts, risks and opportunities (IROs) of both our own operations and our upstream and downstream value chain. For a visualisation of our value chain, please refer to page 9. The extent to which our policies, actions and targets include our value chain depends on our double materiality assessment. We have applied transitional provisions relating to some value chain information; please refer to the topical sections for additional information.Sources of estimation and outcome uncertaintyThe use of estimates for performance metrics, including when upstream and downstream value chain data is included, is described in the individual accounting policies. Overall, metrics related to our own operations have a higher amount of primary data, while value chain metrics are often estimated and therefore have a higher level of measurement uncertainty. All assumptionsand potential uncertainties are documented in the accounting policies. Forwardlooking information, such as targets, are uncertain in nature and we refer to thesection 'Forward-looking statements' on page 35 for further details.Changes in preparation, presentation or due to specific circumstancesRestatements of historical data due to reporting errors in previous periods, and/or changes to accounting policies, are only performed if the materiality threshold defined in our restatement guidelines is exceeded. Management provides the specific disclosures required by CSRD unless the information is not applicable or is considered immaterial to the decision-making of the primary users of the Sustainability statement. Restatements are primarily due to improvements in calculation methodology or new scientific evidence as we continuously work to improve the accuracy of our sustainability reporting. In 2024, the organisational scope of some metrics was expanded to include all entities, but this has not resulted in any restatements.In 2024, the following metrics have been restated due to improved calculation methodology: the comparative figures for total scope 3 GHG emissions and its categories 1 (Purchased goods and services), 2 (Capital goods), 4 (Upstream transportation and distribution) and 6 (Business travel), vulnerable patients reached with Diabetes care products, rate of recordable work-related accidents for own workforce, and number of substantiated cases reported within accounting issues, fraud and business ethics matters via the Compliance Hotline. For more information, see sections 2.1 'Climate change', 3.1 'Patient protection and quality of life', 3.2 'Own workforce' and 4.1 'Business conduct'.Comparative figuresComparative figures are provided for metrics that have been disclosed in one or more prior periods, where their definition and scope were aligned with the ESRS requirements or required only minor adjustments. In accordance with the ESRS transitional provision, no comparative figures are disclosed for new metrics introduced in 2024.Incorporation by referenceAn overview of all incorporation by references used within the Sustainability statement is listed in section 5, table 3. Statement on sustainability due diligence Novo Nordisk performs due diligence activities relating to people and the environment. The table below outlines the specific processes and their location in the Sustainability statement.Core elements of environmental and social due diligence Pagesa)Embedding due diligence in governance, 50-55, 60, 64, 65, 67,strategy and business model68, 71, 80, 88, 90b)Engaging with affected stakeholders in 50-52, 60, 66, 68, 72, 80,all key steps of the due diligence86, 88, 90, 91, 94, 95c)Identifying and assessing adverse impacts52-55, 60, 64, 65, 67, 71, 80, 88, 90d)Taking actions to address those 55, 56, 60-61, 64, 66, 68, 72-74, adverse impacts76-79, 81-82, 84, 86, 89, 90-92, 94e)Tracking effectiveness of these efforts 55-59, 62-68, 74,and communicating75, 82-87, 91-931.3 Sustainability governance The role of the Board of Directors and Executive ManagementSustainability matters are addressed in relevant governance bodies across the organisation to ensure integration into Novo Nordisk's strategy and core business.Our sustainability governance is anchored with the Board of Directors, which has the overall responsibility of providing oversight and advice on sustainability matters, including the strategic direction and ambition level as set by Executive Management. In addition, the Audit Committee assists the Board with oversight of financial and sustainability reporting while the Remuneration Committee and the People and Governance Committee assist the Board in ensuring integration of sustainability into our executive remuneration and board competency assessment, respectively. The oversight and relevant reporting lines are outlined in the visualisation on the right, including approval of our sustainability reporting of material impacts, risks and opportunities, target performance and variable remuneration components. The mandates outlined are addressed in relevant governance documents pertaining to each of the governance bodies.Strategy and targets are set by Executive Management, who is responsible for material sustainability matters in the day-to-day management of Novo Nordisk. In March 2024, the Board of Directors and Executive Management attended an educational session on sustainability trends and key topics, which included a discussion of the double materiality assessment and a deep-dive on nature and biodiversity, to increase their expertise with regards to specific impacts, risks and opportunities.Operational decisions are delegated to management level, with the Sustainable Business Execution Steering Group â comprising senior representatives from across the business â providing guidance on implementation of our environmental, social and governance-related disclosure initiatives. In addition to the dedicated sustainability steering groups, sustainability is also integrated into existing governance structures, such as our product governance, where we aim to integrate social and environmental considerations across product lifecycles.We actively seek external input through our Sustainability Advisory Council, an independent body offering perspectives that challenge us to improve our sustainability efforts continuously. See more about the council and its members at: www.novonordisk.com/sustainable-business/esg-portal.html.Reward structures at Novo Nordisk are designed to support our strategy and motivate our executives to deliver sustainable growth and successful outcomes in relation to our strategic aspirations. Both the short- and long-term incentive programmes include sustainability-related metrics, such as our target on GHG emissions, aligning with Novo Nordisk's sustainability-related objectives.For further details on sustainability governance and remuneration of the Board of Directors and Executive Management, we refer to the incorporation by reference table 3 in section 5, on page 96.Risk management and internal controls over sustainability reportingAt Novo Nordisk, risks and controls over sustainability reporting are assessed annually. We assess risks associated with incomplete or inconsistent sustainability reporting, including risks related to the accuracy of data and manual errors when consolidating data from different systems. We use a centralised, online repository to document our financial and sustainability-related risks and controls and focus on the highest risks. With regards to the double materiality assessment, we performed controls on the process for identifying material impacts, risks and opportunities and underlying documentation.Novo Nordiskâs lines of business and responsible data owners assess the risks associated with sustainability data and implement appropriate controls. A headquarter function maintains an overall risk assessment of sustainability reporting and determines the level of internal controls required for each process, depending on the materiality of the risks. Group Internal Audit conducts independent audits to assess the design and operating effectiveness of the risk and control processes.Executive Management is responsible for the overall internal control framework. The Disclosure Committee â a management committee established by Executive Management â reviews changes to sustainability reporting in the Company Announcement on a quarterly basis. The Audit Committee oversees financial and sustainability reporting and is informed about actions and progress on essential sustainability metrics and targets on a quarterly basis.1.4 Interests and views of stakeholdersNovo Nordisk strives to understand and reflect the interests and views of patients (gathered via engagement with patient organisations), employees, and other key stakeholders across the value chain, through our standard due diligence processes, as we deliver on our sustainability priorities and our doublemateriality assessment. We ensure that the interests and views are taken into account in the strategic direction of Novo Nordisk by informing ExecutiveManagement and the Board of Directors on an ongoing basis as per our sustainability governance.We continuously measure the extent to which we live up to societiesâ expectations through our company reputation score. Novo Nordisk has maintained its 'Excellent' reputation in 2024, achieving a global reputationscore of 81.6 (on a 100-scale) across 20 tracked markets and five stakeholder groups, in line with the performance of 2023.Stakeholder group Patient organisations, healthcare professionalsand healthcare organisations Employees Suppliers and third-party representativesPublic officials and regulatorsPartners and peers Investors Purpose and engagement channelsWe ensure a patient-centred business approach to improve prevention, detection, treatment and access to quality care for people living with serious chronic diseases, through research collaboration and trials, conferences, and scientific and medical communications.We strive to improve health, safety and wellbeing of our employees. Talent attraction and retention, driving innovation and providing employees with equitable opportunities to realise their potential, are essential to our strategy. We enable this via our annual employee survey, Evolve, individual career development and training, workersâ councils, ongoing socialdialogue, and investing in onboarding of new employees. Our Responsible Sourcing Programme, human rights due diligence and established contracting and engagement processes drive our supplier and third-party engagement. We leverage this when purchasing goods and services to manufacture or distribute pharmaceutical products and partnering with third-party representatives, for example on filling or assembling final products or performing clinical trials.To advocate for improvement of public health and meet current and future regulatory requirements we organise and sponsor events, engage with industry associations, drive bilateral dialogues with local, national and international agencies and authorities. We seek perspectives from partners and peers to advance on many of our commitments, especially when it comes to our access and prevention efforts. Example of such collaborations include our Sustainability Advisory Council, Cities for Better Health, and other industry partnerships.We strive to provide timely, accurate and transparent information to our investors through engagements such as Capital Markets Day, the annual general meeting, ESG raters and rankers, and recurring engagement in response to investor queries.Examples of how outcomes are taken into account⢠Development of new treatments and product improvements.⢠Efforts to strengthen the resilience of healthcare systems, for example through prevention efforts.⢠Novo Nordisk Way facilitations to live up to our cultural commitments.⢠Fostering a culture of safety with attention to increase employee health and total wellbeing.⢠Improving employee benefits, for example parental leave.⢠Renewable electricity commitments in our supply chain. ⢠Informed supplier and third-party representative selection.⢠Enable new innovation.⢠Improve existing healthcare to the benefit of patients. ⢠Advance our environmental commitments, for example through Sustainable Marine Fuels (SMF) and lower carbon plastics.⢠Prevent childhood overweight and obesity through UNICEF partnership and the Childhood Obesity Prevention Initiative with partners such as city governments and academic institutions.⢠Provide input to sustainability strategies and targets.⢠Strengthened sustainability performance, reporting and communication efforts.1.5 Double materiality assessment Processes to identify and assess material impacts, risks and opportunitiesIn 2024, we completed a double materiality assessment in accordance with the requirements of ESRS 1 to determine material sustainability topics for the entire Novo Nordisk Group. The assessment considered both the impacts of our business on society and the environment (impact materiality) and how sustainability topics affect the Group in the form of business risks and opportunities (financial materiality). In addition, we considered the 1 implementation guidance provided by EFRAG(EFRAG IG 1), including how to set qualitative and quantitative thresholds, and previous materiality analyses. Results will be reviewed annually.The double materiality assessment was initiated combining the list of sub-sub-topics as per ESRS 1 with additional entity-specific sustainability matters, in consideration of Novo Nordiskâs industry, using screening tools and existing voluntary standards. Furthermore, an outside-in perspective was considered, by consulting our stakeholders and actors in the value chain. All identified topics have followed a four-phase process: 1) input from internal subject matter experts; 2) engagement with external stakeholders; 3) calibration by internal leaders including discussion by senior management; and 4) Audit Committee review and approval.Subject matter experts in our workforce provided initial input by scoring relevant topics related to their areas of expertise, through a survey covering the full scope of the Novo Nordisk Group. The scores were accompanied by qualitative rationales that included considerations of specific geographies, processes, due diligence findings and actors across the value chain to identify material IROs.By using an average scoring approach, impacts were assessed based on their scale, scope, irremediability (in the case of negative impacts) and likelihood; and risks and opportunities on their magnitude, likelihood and type of financial effect. Likelihood was assessed only for potential IROs.The methodology to determine impact materiality was largely aligned with EFRAG's implementation guideline, assessing scale, scope and irremediability against qualitative criteria. For scale, we assessed the size of the impact to the environment and people; for scope its reach or geographical span and, where 1. European Financial Reporting Advisory Group, a private association providing technical advice to the European Commission on both financial and sustainability reporting standards. applicable, irremediability scores considered how difficult it would be to remedy our negative impacts.The methodology to determine financial materiality was largely aligned with Novo Nordiskâs enterprise risk management framework, including the quantitative and qualitative scales and the different types of the financial effects: classified as monetary, reputational, ethical or quality-related. The main differences to the enterprise risk management framework include longer time horizons and the risks being assessed before mitigating actions in accordance with ESRS 1. We will continue to assess how sustainability is considered in our overall risk profile, to strengthen our integrated risk management process.External stakeholder groups were involved through surveys of: a selection of international patient organisations (serving as proxy for our patientsâ interests across different therapy areas), a selection of our top 20 investors by ownership size; and a selection of Tier 1 suppliers across different sourcing categories. Affected communities were not directly consulted. Other consultations are specified in relevant sections of the Sustainability statement. Additionally, we used a data analysis tool to reflect the perspectives of wider society, using sources such as peersâ public reports, regulatory guidance and news.The preliminary results were aggregated, discussed and calibrated at workshops with sustainability leaders from various functions in the Group and by senior management. This was to include a top-down perspective, prevent subjective bias and ensure consistency across the sustainability topics.IRO conclusions were determined against our pre-defined thresholds. For impact materiality, all sustainability topics classified as critical, significant and important and considered current or likely/very likely to occur, were deemed material (see double materiality assessment illustration on the next page). For risks and opportunities, a sustainability topic was considered financially materialwith scores categorised as critical and significant if either current or likely/very likely to occur. The thresholds for impact materiality were set lower than those for financial materiality, reflecting our commitment to transparency of our impacts on and contributions to society and the planet. The results of the double materiality assessment and material IROs were reviewed and approved by the Audit Committee.We have mapped the material IROs to the applicable ESRS data points and further assessed their materiality, to determine whether they were relevant for our business model and/or for the decision-making needs of the users of the Sustainability statement. This analysis determined the material sustainability information disclosed in this Sustainability statement.Interaction with strategy and business modelThe results of our double materiality assessment reflect Novo Nordisk's sustainability strategy and business model. Our positive, social impacts associated with providing access to life-saving medicines without compromising safety or quality, help to improve quality of life and healthcare systems for people around the world. For an overview of our products, see section 'Innovation and therapeutic focus' on pages 17-25. To remain a relevant and attractive workplace, we depend on people's wellbeing, within and outside our operations, to contribute to continued innovation to society. The results also underscore our negative environmental impact when manufacturing medicine, including associated carbon emissions and plastic footprint. Coupled with our dependence on nature-based resources, our environmental strategy strives to limit any such negative impacts. We acknowledge the impacts of our business conduct, and of upholding the highest ethical standards in order to continue to be respected for our societal contributions..To assess the resilience of Novo Nordisk's strategy and business model, sustainability is included in our annual strategy review. Executive Management and the Board of Directors meet annually to discuss strategic risks and opportunities within and beyond the next five years to ensure that we continue to meet societyâs needs. Discussions include sustainability impacts such as how we reach more vulnerable patients while striving to minimise environmental impacts.Resilience discussions are based on input and recommendations from across the organisation with a focus on the topics that are most likely to impact our long-term strategy and forward-looking trend analyses, resulting in adjustments to the strategy if necessary. Sustainability is therefore integrated in relevant functional strategies and sustainability strategies are discussed on an ongoing basis with Executive Management. Descriptions of topic-specific resilience analysis are included where relevant in the topical sections. For more on our strategy that relates to sustainability matters, see section 'Purpose and sustainability' on pages 12-16.Outcomes of the double materiality assessmentThe illustration to the right provides an overview of the material IROs associated with each material sustainability topic and where the IROs are in our business model across time horizons. Climate change, resource use and circular economy, patient protection and quality of life, and own workforce are all essential sustainability topics to Novo Nordisk, reflecting our focus of managing the associated impacts, risks and opportunities through our strategic priorities. Furthermore, water, pollution, biodiversity, workers in the value chain and business conduct are all important sustainability topics where Novo Nordisk has impacts, but is not materially affected by related risks or opportunities. A detailed description of the material IROs is given in the topical sections of this Sustainability statement.We focus on setting strategic targets for our essential topics as these are considered our top sustainability priorities. For other important sustainability topics we measure progress against relevant metrics or project KPIs as specified for relevant actions in each topical section.2. Environment2.1 Climate changeAs a global company with sourcing, manufacturing, and distribution to reach patients across the world, Novo Nordisk has impacts on climate change and the environment. We address these impacts through the execution of our Circular for Zero strategy, including decarbonising our own operations and working with our suppliers to reduce GHG emissions across our value chain.Material impacts, risks and opportunities (IROs) Identified IRO Category Value chainCO2e emissions across our operations and value ⢠Upstream chain contribute to climate change⢠Own operations⢠DownstreamPotential reputational risks associated with rising ⢠Upstream CO2e emissions⢠Own operations⢠DownstreamThe majority (96%) of Novo Nordiskâs GHG emissions originate in our upstream and downstream value chain, from sourcing and services to distributing our products (scope 3). GHG emissions from our own operations (scopes 1 and 2) have a relatively lower impact (4%). Our emissions have a negative impact on global warming, while material transition risks of our climate change mitigation efforts include potential reputational risks associated with an increase in GHG emissions.Identified IRO Category Value chainPotential weather-related hazards impacting safety at ⢠Upstream our sites and in our value chain⢠Own operations⢠DownstreamWeather-related hazards could potentially have negative impacts on the protection of employees or workers in the value chain, as well as on patients' health and wellbeing if access to treatments is disrupted. The worst impacts from climate-related weather hazards will likely materialise in the medium- and long-term and are currently not considered financially material to Novo Nordisk. However, we continuously assess physical climate risks and the extent to which they could impact our operations and value chain, as described in this section.Based on our climate adaptation efforts and decarbonisation initiatives throughout our value chain, we assess that our strategy is resilient in relation to climate change. This assessment was made based on the processes described below, including a high-level climate scenario analysis conducted in 2024. Processes to identify impacts, risks and opportunitiesTo identify our climate impacts, we track our GHG emissions by monitoring our direct emissions and energy consumption across sites, as well as emissions in our upstream and downstream value chain through supplier data, activity data and financial data. We screen our activities to assess actual and potential climate impacts in line with our corporate strategy and decarbonisation roadmap.Climate-related risks are identified and assessed as part of Novo Nordiskâs risk management process and systems (see section âRisk managementâ on page 39 with regards to the main strategic risk 'environmental impact'). Short- and medium-term climate risks are assessed across business areas, while long-term risks are assessed as part of our company-wide strategic risk identification process. When identifying material climate risks, the same time horizons have been applied as for the double materiality assessment, with climate-related risks expected to materialise in the long-term (beyond 5 years). We use natural hazard screening for all relevant physical hazards at our production sites and in our supply chain, excluding warehouses, on an annual basis and as part of our sourcing due diligence process. Transition risks are assessed qualitatively in accordance with the double materiality assessment methodology. In 2024, we conducted a forward-looking, high-level assessment of physical and transition climate-related risk, considering a 4°C and a 1.5°C scenario to capture how âbusiness as usualâ and rapid decarbonisation pathways would each impact our business. For physical risks, the analysis was performed under high emission Representative Concentration Pathway (RCP) 8.5 and a low emissions RCP 2.6. pathway across 2030- and 2050-time horizons, focusing on selected raw materials and on acute and chronic hazards. This was done using an external meteorological database, as well as asset information and geospatial coordinates for production sites. Transition risks were modelled using an Integrated Assessment Model (IAM) scenario analysis tool to account for sector- and region-specific macroeconomic shifts and considering energy supply, raw material pricing, labour cost, and revenue changes. No aspects of our business were identified as incompatible with a transition to a climate-neutral economy.Mitigation, adaptation and energyPoliciesPolicy Environmental policyPurpose Guides action across material environmental topicsScope All of Novo Nordisk's global activitiesMost senior level Executive ManagementaccountableAvailability Externally available: Our environmental policyApplicability across ⢠Climate change, page 54Sustainability statement⢠Resource use and circular economy, page 60⢠Pollution, page 64⢠Water, page 65⢠Biodiversity and ecosystems, page 67Novo Nordiskâs environmental policy states our commitment to ensuring treatment for people living with serious chronic diseases with the lowest possible impact on the environment, by reducing our GHG emissions in line with the Science Based Targets initiative (SBTi). As such, the policy sets out a key objective of mitigating our climate impact through energy efficiency measures, deployment of renewable energy, and other decarbonisation levers as detailed further in this section. The policy also states our commitment to protecting the business through evaluating climate-related risks and taking measures to adapt to climate change.Implementation of the environmental policy is ensured by management teams across the business and by on-site environmental partners at all production facilities globally, who safeguard compliance and continuous improvements. Our production facilities are ISO 14001 certified for environmental management to ensure continuous improvements and mitigate, control and prevent negative environmental impacts. Actions and transition plan for climate change mitigationTo mitigate our impacts on climate change, Novo Nordisk is committed to reaching net zero emissions across scope 1, scope 2 (market-based) and scope 3 GHG emissions by 2045 in alignment with the Corporate Net-Zero Standard from the SBTi. In addition, we have targets of zero scope 1 and scope 2 (market-based) CO2e emissions by 2030, and a new target of 33% absolute reduction of scope 13 CO2e emissions by 2033 compared to our base-year of 2024. The targets havebeen approved by our Board of Directors and Executive Management. Our new scope 3 target is not 1.5â aligned, but is consistent with SBTiâs well-below 2.0â pathway. We will start executing the transition plan in 2025 to achieve our scope3 target by 2033. However, many of our scope 3 decarbonisation levers will not materialise until at least 2030. With the projected growth and the delayed effect of our decarbonisation levers, we anticipate an overall growth in GHG emissionsuntil 2030 compared to the baseline.We have made progress in reducing our environmental impact since the launch of our Circular for Zero strategy in 2019, including converting to renewable electricity in our own operations and among suppliers, and curbing the climate impact from transportation. In 2024, we updated our scope 3 decarbonisation roadmap, expanding the scope of our target from operations and transportation to cover our operations and value chain globally. The roadmap is aligned with Novo Nordisk's overall business strategy, taking into account our projected growth. Our growth increases the challenges of decarbonising and thus underscores the importance of decoupling our ability to serve more patients 2from our climate impact, to lower GHG emissions. The expected reductions, including anticipated growth in emissions, are currently estimated at 2,200 thousand tonnes of CO2e across scope 3 by 2033. This includes initiatives already identified, estimated at 1,500 thousand tonnes CO2e, and therefore a gap towards our target of an estimated 700 thousand tonnes of CO2. We will address these remaining emissions as we progress with implementing the roadmap and assess the scalability and effectiveness of identified initiatives, while investigating additional levers such as potential new technological advancements. Furthermore, we estimate 131 thousand tonnes of CO2e of expected reductions across scope 1 and 2 by 2030. The expected GHG emission reduction pathway is illustrated on page 57.1. The target covers nearly 70% of our scope 3 emissions in accordance with SBTi provisions. Read more on page 57.2. Expected reductions is defined as the overall quantitative contribution to achieve the GHG emissionreduction targets from all decarbonisation levers, including expected growth projections.Emission reduction efforts in our own operations (scope 1 and 2) are focused on switching to renewable energy sources and increased energy efficiency. Within our upstream and downstream value chain (scope 3), which generates 96% of our total GHG emissions, key levers include converting to lower carbon materials, requiring that our tier 1 suppliers convert to renewable energy, and lowering the emissions from our distribution, as detailed in the table on the next page. Beyond 2033, Novo Nordisk expects to use carbon removals to neutralise residual CO2e emissions of up to 10% of the baseline emissions towards our net zero 2045 target, in line with SBTi requirements and guidance from the Intergovernmental Panel on Climate Change (IPCC). We are exploring opportunities for removing and storing GHG involving both nature- and technology-based solutions. Our potential locked-in GHG emissions are limited but relevant in relation to our partially fossil-fuel-powered production sites, which we are working to convert to electric and renewable energy. We strive to expand our production capacity in a sustainable way, and in 2024 we aligned a proportion of the buildings in two of our capacity expansion projects to the EU Taxonomy, resulting in 6% aligned CapEx in 2024 (3% 3including Catalent), thus contributing to climate change mitigation. See section 2.6 'EU Taxonomy' on page 69 for more information on our approach and ambitions to align future capacity expansion projects where feasible. We continuously invest in integrating our Circular for Zero priorities across our business as part of how we operate, from working with suppliers and designing our manufacturing processes to reducing the end-of-life impact of our products. Further, we will commit additional resources to accelerate the implementation of our updated environmental roadmaps developed in 2024 across climate, plastic and nature. In addition, extended value is created through grants to health, sustainability and the life science ecosystem, via our unique ownership structure, by the Novo Nordisk Foundation, our majority shareholder through Novo Holdings A/S. We also expect to update our incentive programmes, described in our Remuneration report as referenced in Table 3 on page 96, to reflect our new decarbonisation roadmap.3. Novo Nordisk is not excluded from the EU Paris-aligned Benchmarks.Key action to addressclimate change Energy efficiency and optimisation (scope 1 and 2)Switching to renewableelectricity (scope 2)Reducing emissions from heat and steam (scope 1 and 2)Remaining scope 1 and2 emissions reductionsReducing emissions from high impact sourcing categories (scope 3, category 1 and 2)Reducing emissions from product distribution (scope 3, category 4 and 9)Climate adaptation Description and year of completionSites and processes are optimised through our energy savings programme, rethinking the design of our site infrastructure to ensure a resource-efficient energy supply, for example through the construction of a district cooling ring at site Kalundborg, Denmark, to be completedin 2026. Energy efficiency and optimisation across sites is an ongoing action until at least 2030. Reach 100% renewable electricity for Novo Nordiskâs own production sites and affiliates, continuously striving for best practice solutions. Action is ongoing until at least 2030. To reach zero CO2e emissions from production, we are converting steam and heat in our production processes towards renewable energy sources by electrifying processes and coveringnatural gas consumption by biogas certificates. Action is ongoing until at least 2030. Main reductions from remaining scope 1 and 2 GHG emissions will come from lowering emissions from refrigerants, back-up systems and transitioning fossil-based vehicles in own operations to battery electric or plug-in hybrid vehicles. Action is ongoing until at least 2030. Reducing emissions from high impact sourcing categories through three focus areas: 1) converting to lower carbon raw materials and feedstocks for our device and drug manufacturing, as well as lower carbon construction materials; 2) process optimisations to lower material use; 3) renewable energy for tier 1 suppliers. Action to be implemented from 2025-2033.Lower distribution emissions by air, sea, and road: 1) by air, converting additional upstream air freight to sea freight, while securing Sustainable Aviation Fuel (SAF) via long-term off-take agreements; 2) by sea, securing Sustainable Marine Fuel (SMF) in upstream distribution; 3) by road, through low-carbon road freight solutions upstream and downstream. Action to be completed by 2033.To address physical climate risks faced by some of our sites in the medium and long term, all medium- and high-risk sites are covered by mitigation plans, including procedures in cases of a temporary production shutdown and safety rooms for employees, as well as leak detection, drainage, and protection against storm surge. The natural hazard exposure of our 400 most critical suppliers is reviewed as part of our comprehensive supply chain risk assessment. Scope of actionOwn operations globally Own operations globally Own operations globally Own operations globally Supply chain globally Upstream and downstream distributiongloballyOwn production sites andsuppliersTarget in placeYesYesYesYesYesYes No Overall progress in 2024 and how we track effectiveness⢠Progressed with the construction of district cooling ring at site Kalundborg, Denmark, with expected energy savings of over 20,000 MWh/year after completion in 2026.⢠In 2024, energy savings initiatives across sites resulted in total energy reduction of 13,740 MWh.⢠Maintained 100% of Novo Nordiskâs electricity consumption procured from renewable energy sources at all production sites.⢠Continued the transition towards renewable electricity at our affiliates, reaching 99% coverage.⢠Progressed plans to electrify heat and steam production where possible and to cover the natural gas consumption of sites in the US with biogas (renewable natural gas) certificates.⢠Energy consumption from renewable resources accounted for 54% of total energy consumption (excluding steam and heat derived from biomass).⢠Continued the transition away from fossil-based vehicles with market-specific guidance based on local infrastructure conditions.⢠To date, more than 1,800 suppliers have committed to transitioning to renewable power. ⢠In 2024, initiatives were identified together with suppliers and relevant business units across Novo Nordisk, which are expected to account for the majority of scope 3 emission reductions. ⢠Effectiveness is assessed on a quarterly basis through tracking estimated GHG emissions.⢠Initiatives identified together with suppliers and relevant business units across Novo Nordisk.⢠Effectiveness is assessed on a quarterly basis through tracking estimated GHG emissions. ⢠Conducted an updated assessment based on new tools and data, including several new suppliers and acquisition sites, in addition to own sites.⢠Effectiveness of actions are tracked through an annual NatCat report, distributed to own sites to ensure cross-site learning and best practice.PerformanceGHG emissions targetsWe set GHG emission reduction targets across scope 1 and 2 (market-based) and scope 3. The base year is 2024, which is considered representative of Novo Nordisk's business activities. Our scope 3 target covers nearly 70% of our scope 3 emissions, in accordance with the SBTiâs provision of postponing up to one third of base year GHG emissions associated with the highest estimation uncertainty and lowest abatement potential. Hence, categories 3, 5, 7, 12, and 5a part of category 1 and 2 are not included in the scope of the 2033 target. The target is derived using a sectoral decarbonisation pathway and has been submitted for validation by SBTi. Our 2045 net zero target covers all emissions across scope 1, 2 and 3.5. Categories 1 - Purchased goods and services, 2 - Capital goods, 3 - Fuel- and energy-related activities, 5 - Waste generated in operations, 7 - Employee commuting, 12 End-of-life treatment of sold products.In setting the scope 3 target, we estimated projected emissions based on the most ambitious growth forecasts aligned with expected production volumes and expansion projects between 2024 and 2033. To identify and assess the feasibility of decarbonisation levers, we engaged with selected suppliers and with business units across Novo Nordisk. Achieving our targets depends in part on the availability of lower carbon technologies and materials that meet our quality standards as part of the general transition to a lower carbon economy. We will monitor the effectiveness of our targets starting in 2025. Progress on GHG emissionsIn 2024, during the process of developing a new scope 3 target, we have updated our methodology to provide a more reliable data foundation for our target baseline. The current methodology has been reviewed and adjusted across the most material scope 3 categories as follows: ⢠Purchased goods and services (category 1) updates include a combination of transferring contract manufacturing categories from spend- to activity-based accounting, adjustment of emission factors and volume conversions.⢠Capital goods (category 2) updates include adjusting existing spend-based factors, using supplier-specific information when available, and developing new spend-based factors from bills of material. ⢠Emission factors of Upstream transportation and distribution (category 4), and Business travel (category 6) have been updated.The review indicated that categories 1 and 2 were previously overstated due to the inherent uncertainty of spend-based emission factors. We have therefore restated scope 3 GHG emissions for 2023. Our efforts to enhance the accuracy of our scope 3 inventory will continue with a further focus on the less material categories. The inherent uncertainties in scope 3 calculation methodologies, together with ongoing scientific advancements, mean that the risk of future restatements will continue to be present for this metric. In 2024, approximately 12% of scope 3 emissions were calculated using primary data.In 2024, Novo Nordiskâs gross scope 1 and 2 (market-based) emissions grew by 9% and 7% respectively due to the increase in natural gas consumption in our US production and at our newly acquired site in Ireland, Athlone; and the increased consumption of fossil-based steam in China. Scope 3 emissions increased by 24% due to substantial investments in production capacity and increase in supply chain activities to serve more patients. Combined categories 1 (Purchased goods and services) and 2 (Capital goods) account for almost 80% of total scope 3 emissions. These categories are part of our efforts to increase supply to reach more patients and responsible for the majority of the increase in scope 3 emissions in 2024. Our efforts to decarbonise categories 4 (Upstream distribution) and 6 (Business travel) have been challenged by the growth of the company. The procurement of sustainable aviation fuel (SAF) and sustainable marine fuels (SMF) have helped to curb the growth. In 2024, we disclosed for the first time our biogenic emissions, which amounted to 110,000 tonnes CO2e. Biogenic emissions, sometimes referred to as out-of-scope emissions, originate primarily from the procurement of biogas and bio-based steam, and the combustion of bio-based fuels (wood).62.1.1 Scope 1, 2 and 3 GHG emissionsUnit 2024 2023 2022 % changeScope 1 GHG emissions 1,000 tCO2e 85 78 76 9%Percentage of scope 1 GHG emissions from regulated emission trading schemes % 0.3 â â âBiogenic emissions (Out-of-scope emissions) scope 1 1,000 tCO237 â â âScope 2 GHG emissions â location-based 1,000 tCO2e 174 â â âScope 2 GHG emissions â market-based 1,000 tCO2e 16 15 16 7%Biogenic emissions (Out-of-scope emissions) scope 2 1,000 tCO273 â â âScope 1 and 2 (market-based) GHG emissions 1,000 tCO2e 101 93 92 9%Scope 3 GHG emissions 1,000 tCO2e 2,160 1,743 â 24%7⢠Category 1: Purchased goods and services1,000 tCO2e 1,215 1,018 â 19%7⢠Category 2: Capital goods1,000 tCO2e 465 303 â 53%⢠Category 3: Fuel- and energy-related activities 1,000 tCO2e 74 56 â 32%7⢠Category 4: Upstream transportation and distribution1,000 tCO2e 101 108 â (6%)⢠Category 5: Waste generated in operations 1,000 tCO2e 6 6 â 0%7⢠Category 6: Business travel1,000 tCO2e 188 154 â 22%⢠Category 7: Employee commuting 1,000 tCO2e 52 43 â 21%⢠Category 9: Downstream transportation and distribution 1,000 tCO2e 57 52 â 10%⢠Category 12: End-of-life treatment of sold products 1,000 tCO2e 2 3 â (33%)Percentage of scope 3 GHG emissions calculated using primary data % 12.3 â â - Total GHG emissions â location-based 1,000 tCO2e 2,419 â â - 8GHG emission intensity, location-based (total GHG emissions per net revenue) tCO2e/mDKK 8.3 â â - Total GHG emissions â market-based 1,000 tCO2e 2,261 1,836 â 23%8GHG emission intensity, market-based (total GHG emissions per net revenue) tCO2e/mDKK 7.8 â â - 6. Operational control = financial control approach. 7. 2023 figures have been restated for categories 1, 2, 4 and 6 from 2,067; 1,315; 113 and 83 thousand tonnes CO2e, respectively, as disclosed in the Annual Report 2023. 8. Please see note 2.1 'Net sales and rebates' on page 107 in the Consolidated financial statements. Average annual 92.1.2 Scope 1, 2 and 3 GHG emissions targets Unit 20242030 2033 2045reduction Target type TargetScope 1 and 2 (market-based) GHG emissions 1,000 tCO2e 101 0 0 0 17% Absolute (100%)1011Scope 3 GHG emissions1,000 tCO2e 1,493 â 1,000 04% Absolute (33%)9. Base year. 10. The target covers nearly 70% of our scope 3 emissions in accordance with SBTi provisions. Read more on page 57. 11. Novo Nordisk estimates residual emissions after the decarbonisation levers to be 150 thousand tonnes CO2e. Progress on energy consumptionIn 2024, energy consumption from own operations increased by 33%. More than half of this increase is due to the inclusion of car fuel in the metric, that was previously not included. The remaining increase is due to higher consumption of steam, electricity and natural gas. In line with our major decarbonisation levers, we continued working with energy-saving and optimisation projects during 2024, as detailed in the table of key actions on page 56. Total energy consumption from contractual renewable sources â primarily renewable electricity and biogas â accounted for 54% of total energy consumption. The remaining 46% of energy consumption originated from fossil and other sources, of which fossil sources accounted for approximately 474 thousand MWh and non-contractual biomass for further 173 thousand MWh. We adopt a conservative approach when differentiating between renewable and non-renewable sources for electricity, steam, and heat. Only energy specified as renewable in the supplier's contractual agreement is classified as renewable energy. Due to this conservative approach, steam and heat derived from biomass are not included under renewable sources.In 2024, almost all of Novo Nordiskâs electricity consumption was procured from renewable electricity. Since 2020, Novo Nordisk has transitioned to sourcing renewable electricity for all production sites with a range of solutions, primarily Power Purchase Agreements (PPA), Renewable Electricity Certificates (REC), and Guarantees of Origin (GO). All our production sites now source renewable electricity, as do the majority of our offices and laboratories. 2.1.3 Energy consumption and mix Unit 2024 2023 2022Total energy consumption related to 12own operationsMWh 1,400,228 1,051,111 1,021,389Percentage of fossil sources in total energy consumption % 46% â âPercentage of renewable sources in total energy consumption % 54% â âEnergy intensity (total energy MWh/13consumption per net revenue)mDKK 4.82 â â12. Equals to total energy consumption from activities in high climate impact sectors. 13. Please see note 2.1 'Net sales and rebates' on page 107 in the Consolidated financial statements.ACCOUNTING POLICIES Scope 1 GHG emissions The reporting of scope 1 and 2 CO2e emissions follows the ESRS and GHG Protocol Guidance. Includes CO2e emissions from fuels, as well as fugitive emissions of purchased refrigerants. Production sites report all leaks of more than 1 kg refrigerant from cooling systems with a filling of more than 1 kg. Emission factors for the respective energy types are the most recent available from third parties, such as the US Environmental Protection Agency and the UK Government GHG Conversion Factors for Company Reporting. GHG removals, carbon credits and avoided emissions are not included. N2O and CH4 emissions from the consumption of biofuels are included in scope 1 and 2, while bio-based COâ emission are assumed to be zero and are not included but disclosed separately under biogenic emissions. Biogenic emissions refer to out of scope emissions of CO2 from the combustion of biomass- based primary fuels (scope 1) and biomass-derived electricity, steam and district heating (scope 2). Biogenic emissions from our fermentation process are not included due to high calculation uncertainty but we will investigate potential estimation methodologygoing forward.Percentage of scope 1 GHG emissions from regulated emission trading schemesThe share of emissions controlled and managed within the framework of the EU ETS scheme of the total scope 1. Other national and non-EU ETS are not assessed applicable to Novo Nordisk.Scope 2 emissionsIndirect GHG emissions from electricity, heat and steam, purchased and consumed by Novo Nordisk. Location-based emissions are based on national grid average emission factors for defined locations. Market-based scope 2 emissions refer to indirect GHG emissions associated with purchased electricity, heat and steam through procurement of contractual instruments such as Energy Attribute Certificates, Power Purchase Agreements and Guarantees of Origin from sources such as wind, hydro, solar and biomass. For sites without such contractual agreements and for other scope 2 energy types in the absenceof supplier specific emission factors and / or residual mix emission factors, the national average emission factor has been applied. Scope 3 emissionsIndirect GHG emissions that originate from our value chain. Novo Nordisk has identified nine categories of scope 3 emissions out of the fifteen defined by the GHG Protocol as significant. The remaining six categories are not reported on separately, as they are either not applicable to Novo Nordisk or have been included in the other emission categories. Accounting policies are detailed only for the two most material categories of scope 3 â category 1 and 2.Our calculation methods for remaining categories 3, 4, 5, 6, 7, 9 and 12 are in line with the GHG Protocol and include the supplier-specific method, distance-based approach, average-activity method, average spend-based method and other hybrid method. In general, major sources of emission factors include DEFRA, EXIOBASE, GaBi and other industry databases and standards. Category 1: Purchased goods and servicesEmissions related to all spend from external suppliers, except for investment spend and travel categories, which are included in other scope 3 categories. Purchased goods and services mainly comprise raw materials for products, marketing, packaging materials and consumables for laboratory and IT office equipment. Direct spend is converted into CO2e emissions using the average data method. Material weights are matched with CO2e factors depending on data availability. A spend-based factor is applied for direct spend data where no weight can be obtained. Indirect spend is converted into CO2e using a spend-based method. Category 2: Capital goodsEmissions related to all indirect investment spend from external suppliers, mainly production utilities and equipment. Indirect spend is converted into CO2e emissions via the average spend-based method.Percentage of GHG scope 3 calculated using primary dataScope 3 emissions where primary data from suppliers or other value chain partners have been utilised in the calculation. This includes all of category 3, parts of category 4 emissions from inter-site distribution and the distribution of finished products (provided directly by an external supplier managing the transportation and distribution processes), business flights (part of category 6) and two materials of category 1.Total energy consumption from fossil sources under Novo Nordisk controlPrimary energy consumption from coal, crude oil, petroleum products, and natural gas, as well as consumption of externally purchased secondary non-renewable energy such as electricity, heat, steam and cooling; and non-contractual biomass energy. Energy consumption is based on meter readings and/or invoices. In line with the ESRS requirements, we have enlarged the scope of the total energy consumption metric to include all entities under operational control, including fuel consumption in leased vehicles. Total energy consumption from renewable sourcesWood, biogas and externally purchased electricity from renewable sources, such as wind, solar, hydropower, biomass or biogas, as defined in the contractual agreements. Due to the conservative accounting approach requirement, steam and heat derived from biomass are not included under renewable sources. Consumption is based on meter readings and/or invoices and complemented with data on renewable energy certificates for each site. The previously reported metric âShare of renewable power for production sitesâ was adjusted in scope to fully reflect the ESRS requirement.Energy intensity/GHG intensityTotal energy consumption/total GHG emissions per net revenue. For energy intensity this corresponds to energy intensity from activities in high climate impact sectors. It is assumed that all activities of the Novo Nordisk Group are in a high climate impact sector (NACE code C21). Net revenue refers to total net sales generated by Novo Nordisk.2.2 Resource use and circular economyAt the core of our Circular for Zero strategy is our commitment to decoupling resource use and waste from our ability to serve patients. The urgency of innovation in this regard is heightened by the stringent regulatory standards for the pharmaceutical industry, for example restriction of the use of recycled materials in our medicines and devices. Similarly, while many materials in our products are theoretically recyclable individually, the lack of established recycling infrastructure for pharmaceutical products makes this difficult to be achieved in practice. We also recognise the challenges related to the inflow of materials and resources into our construction projects within the upstream value chain.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainResource use and waste associated with ⢠Upstreammanufacturing and products⢠Own operations⢠DownstreamPotential reputational risks related to resource ⢠Upstreamconsumption⢠Own operations⢠DownstreamWhen manufacturing our products, we use materials and rely on natural resources, while also generating waste through our production processes or during our productsâ end-of-life cycle; all of which contribute to negative environmental impacts. Plastic components and plastic raw materials are among our top purchasing categories by weight, together with biological materials such as agricultural commodities and packaging materials, as well as various technical materials used in our manufacturing processes. The impact of sourcing these raw materials has increased in recent years due to our high growth rate, a trend we are working to address by decoupling environmental impact from growth as part of our Circular for Zero strategy. As our devices are core to our business, reputational risks related to our resource consumption are also considered material. Processes to identify impacts, risks and opportunitiesTo assess impacts, risks and opportunities related to our resource inflows and outflows, including waste, we consulted suppliers, investors and patient organisations. We continuously assess impacts and risks through environmental assessments, annually at each production site, and as part of all product development processes. The primary business areas in Novo Nordisk associated with resource use and circular economy are production, supply and sourcing units; however, our efforts to achieve our Circular for Zero ambitions affect all of Novo Nordisk and are core to our operations across the business.Resource inflow, resource outflow and wastePolicies Circularity is the foundation of Novo Nordiskâs Circular for Zero strategy and is anchored in our environmental policy, which states our commitment to designing out waste and pollution and keeping materials in loops, thus addressing our material impacts and risks related to resource use and circular economy. Our environmental policy states our commitment to promoting low impact products and processes, when possible, for example by finding ways to use waste from one process as a resource in another process, including in our TMdownstream value chain through our ReMed programme.We also strive to source reused, recycled, and renewable biological materials, while always considering patient safety and the stringent regulatory requirements applicable to the pharmaceutical sector. As stated in our environmental policy, Novo Nordisk works systematically with third-party-validated life cycle assessments to better understand and reduce the environmental impact of our products. We prioritise the avoidance and reduction of waste over waste treatment where possible. As such, our environmental policy and associated actions related to products and productioprocesses address all levels of the waste hierarchy, from prevention and reuse to recycling, energy recovery and disposal. For information on our reuse of chemicals and treatment of chemical waste and water, see sections 2.3 'Pollution' and 2.4 'Water' on pages 64 and 65, respectively. ActionsNovo Nordisk continuously takes action to reduce resource use, increase circularity, and minimise waste across product design and development, manufacturing, and product end-of-life. To further strengthen these efforts, in 2024 we set new targets for reducing our plastic footprint per patient in addition to our target addressing landfill waste, as detailed further under Performance in this section. The key actions to reach these targets and our wider Circular for Zero objectives are listed in the table on the next page.Key action to address resource use and circular economy Lower-carbon plastics TMReMed: recycling of used pensConverting to reusable devicesCircular design guidelinesInnovating treatment methodsMaking production processes more circularEliminating landfill wasteDescription and year of completionIndustrial partnership to buy e-methanol to produce a lower-carbon alternative to one of Novo Nordisk's top two plastic types. Production is expected to start in 2025 and continue on an ongoing basis, pending completion of plant construction.Take-back scheme to recycle injection pens launched in 2020 in Denmark, and subsequently in six other markets. These seven markets represent approximately 20% of injection pens currently supplied in the market. An industry-wide scheme was launched in Denmark in 2023 with three other pharmaceutical companies as part of our ongoing efforts to address the lack of recycling infrastructures in our industry. Collected pens are recycled by an external recycling partner.Converting from single and multi-use devices to reusable devices, to lower the lifetime environmental impact per product, including developing a cost-efficient reusable pen with a competitive environmental profile across our injection pen portfolio as part of our recurring efforts to increase circularity and reduce our plastic footprint per patient.Guidelines tailored to our devices and packaging and applied to every design process, which consider 1) design for expected lifetime; 2) design for sustainable materials; 3) no unnecessary waste in production; and 4) recyclability after use. This is a recurring action.®Optimising our material use through Awiqli, the worldâs first once-weekly basal insulin, as part of our efforts to reduce our plastic footprint towards 2033. Going from daily to weekly injection reduces the plastic footprint of the treatment by approximately two thirds (comparedto once-daily treatment).Circular production processes, including internal reuse of ethanol at our two largest API production sites, as a recurring action. At site Kalundborg, Denmark, most remaining ethanol waste together with yeast slurry is turned into energy and fertiliser for localfarmers as part of the Kalundborg Symbiosis.Divert waste from landfill to either incineration, other recovery operations or recycling by 2030 to avoid harmful environmental impacts from landfill waste.Scope of actionGlobal, injection devices Denmark, Brazil, France, Italy, UK, Japan, GermanyGlobalGlobalCanada, Germany, and ChinaAPI production in Denmark and USProduction sites globally Target in placeNoNo YesNo YesOverall progress in 2024 and how we track effectiveness⢠Partnership launched in 2024.⢠Tracking to be established in connection with receipt of first batch of materials.TM⢠ReMed initiatives launched in Italy, Japan and Germany. ⢠Return rate of 32% achieved for all injection devices in Danish industry scheme. Recycling rate for returned pens increased from 50% in early 2024 to 70% by end of 2024.⢠Effectiveness is tracked through monitoring return rates across markets in scope. We work continuously on making patients, society and partners aware of the scheme to drive up return rates and increase recycled volumes.⢠Plastic footprint of 0.35 kg/patient in 2024.⢠Development of new reusable device, planned for launch in 2026.⢠Future plans include delivering the majority of daily insulins in reusable devices.⢠Strengthened implementation of circular design framework through organisational anchoring and tools.®⢠Awiqli entered the market for the first time.⢠Resource use is monitored at site level to track our levels of circularity and resource efficiency across production processes, thus enabling the ongoing identification of improvement areas. For example, the reuse of ethanol reduces use of new ethanol by almost 90%.⢠Waste to landfill reduced at site Clayton, US, most of it via waste-to-energy, leading to a significant reduction of landfill waste.PerformanceTargets on plastic footprint per patient and zero landfillTo track the effectiveness of our actions, we have set a global target to reduce our plastic footprint per patient from Diabetes and Obesity products by 30% by 2033, compared to our baseline of 0.35 kg/patient in 2024. This target addresses both resource inflows and outflows, including the minimisation of primary raw materials, thus preventing plastic waste via efforts to convert to reusable devices, circular product design, and innovating treatment methods. The scope of the target includes plastic in devices and primary packaging for Diabetes and Obesity products, and internal experts across areas were involved in setting it.To address our waste impact, we also have a global target of zero landfill from production sites by 2030, thus seeking to redirect waste to incineration or recycling. In 2024, the total volume of production waste directed to landfill was 94 tonnes, hereby we achieved a 92% reduction compared to our baseline (2019). Progress on resource inflowsIn 2024, the overall total weight of products and technical and biological materials used for the manufacture of our medicines amounted to 226 thousand tonnes, with approximately two thirds being technical materialsand one third biological components. We do not currently procure certified sustainably sourced biological materials, leading us to report their share as 0%. In 2024, the total weight of reused or recycled materials was 3 tonnes, primarily from the sourcing of gowning, and recycled pallet shippers and shipper boxes.In addition to plastic components, the main products and materials sourced that relate to resource inflows include biological materials, such as agricultural commodities (for example glucose) and printed packaging, as well as technical materials, such as acids and bases, and solvents. While we do not directly purchase critical raw materials and rare earths, some purchased items include critical raw materials such as magnesium, manganese, and phosphorus. Resource outflows leaving Novo Nordiskâs facilities include medicines, injection devices, packaging materials, and waste.Progress on resource outflowsThe durability of our prefilled devices is determined by the shelf-life of the medicine and the number of doses it contains. Durability is estimated between 24 and 36 months and approximately 7 uses, depending on the medical substance. Reusable devices have a durability of 60 months, which is at the higher end of the industry range. 2.2.1 Resource inflows Unit 2024 2023 2022Overall total weight of products and technical and biological materials used during the reporting period 1,000 tonnes 226 â âPercentage of biological materials (and biofuels used for non-energy purposes) that are sustainably sourced % 0 â âAbsolute weight of secondary reused or recycled components, secondary intermediary products and secondary materials used to manufacture the undertakingâs products and services (including packaging) 1,000 tonnes 3 â âPercentage of secondary reused or recycled components, secondary intermediary products and secondary materials % 1 â âNovo Nordisk Industry Novo Nordisk Industry Novo Nordisk Industry 2.2.2 Resource outflows Unit202420242023202320222022Expected durability of unopened prefilled devices Months 24-36 12-36 â â â â⢠Prefilled devices for single use Number of uses 1 1 â â â â⢠Prefilled devices for multiple use Number of uses 7 7 â â â âExpected durability of reusable devices Months 60 12-72 â â â âRecyclable content in products % 0 â â â â âRecyclable content in products packaging % 28 â â â â âPlastic footprint (absolute) Tonnes 15,654 N/APlastic footprint per patient kg/patient 0.35 N/ATarget 2024 2033Plastic footprint per patient % reduction from 2024 N/A (30%)While many components of our devices can be recycled individually, there is no established recycling infrastructure for pharmaceutical waste in many of our markets, and hence we conservatively assume zero recyclable content in products. A conservative estimate of recyclable content in our products' packaging is 28%, reflecting the lowest share of recyclable content according to our productlifecycle assessments. The full range is 28-88%, with the difference being due to varying packaging compositions across our core products and three key geographies (Europe, US and Japan). Data on total packaging weights by geography have not been available for 2024, but it is a priority to establish the data foundation for reporting recyclable packaging across all key products as weighted average in 2025. Progress on resource outflows â wasteNovo Nordiskâs largest waste streams in terms of volume are the generation of organic residue (for example yeast slurry), water waste (waste fraction with a high water content treated as waste) and ethanol waste. The majority of organic residues is diverted from disposal through recycling and other recovery operations. Total waste increased by 21% in 2024, mainly due to increased production volumes (19% increase in waste generated in production) and the inclusion of non-production entities in the total waste metric (2%). 15% of the total waste was directed to disposal and therefore non-recycled, while 85% was recycled, recovered or prepared for reuse. Hazardous waste accounted for 23% of the total, with equal split between further recycling/recovery operations and waste directed to disposal through incineration.2.2.3 Resource outflow â WasteUnit 2024 2023 2022Total waste generated Tonnes 229,690 189,091 213,505Non-recycled waste Tonnes 34,132 â âPercentage of non-recycled waste % 15% â â1Total amount of radioactive waste kg 87â âWaste to landfill Tonnes 120 638 906Progress on target 2024 2030Waste to landfill (production) Tonnes 94 01. 20kg Isotope 125-I solid, 15kg Isotope 125-I Liquid, 15kg Isotope 3-H, solid, and 37kg Isotope 3-H, solid.ACCOUNTING POLICIES Overall total weight of technical and biological products and materialsTotal amount of materials used in our operations. Technical materials cannot be processed by the biological cycle, while biological materials can. Total weight includes all raw materials, associated process materials and semi-manufactured goods or parts sourced into production. Approximately 3% of the total cannot be categorised into biological or technical material but is still included in the total. No material was included in both categories to avoid double-counting. Percentage of biological materials that are sustainably sourced Proportion of biologically sourced materials deemed sustainable, according to our internally approved list of eco-labels (including those from the Forest Stewardship Council (FSC), Programme for the Endorsement of Forest Certification (PEFC), and Rainforest Alliance), in the total materials used. Absolute weight of secondary reused or recycled components Total weight of previously used or recycled materials used in the production process, such as gowning, recycled pallet shippers and shipper boxes. Internal re-use and multiple re-use within Novo Nordisk are not included in the metric, for example the reuse of ethanol and pallets. Percentage of secondary reused or recycled componentsThe weight of secondary reused and recycled materials, components and products divided by the total weight of all materials used.Recyclable content in products and packagingShare of recyclable materials used. Novo Nordisk's definition of recyclable content reflects practical recyclability in line with the Ellen McArthur Foundationâs definition and the EU Packaging and Packaging Waste Regulation. For recyclable content in product packaging, data on total packaging weights by geography have not been available and the metric shows the shows the lower end of the range of recyclable content across markets and not the weighted average.The expected durability of productsFor reusable devices technical durability of the device. For prefilled devices, expected number of uses and anticipated shelf-life for unopened medicines, with shelf-life referring to the expected ability of the products to maintain their stability, efficacy, and quality over a specified period under recommended storage conditions. The metric is a minimum to maximum range per product category for both Novo Nordisk products placed on the market and the industry average available from market research, industry reports, regulatory guidelines, supply chain data and external certifications. Novo Nordiskâs product range is included in the industry average. Number of uses for multi-use prefilled devices is based on the most sold device-medicine combination and the daily dose defined by the WHO.Plastic footprintAbsolute plastic footprint is defined as the total amount of plastic placed on the market by Novo Nordisk in connection with Diabetes and Obesity products, including plastic from Novo Nordisk devices (pens and needles) and primary packaging (cartridges, vials, blister packs and tablet bottles). The metric does not capture additional plastic used in the process. Plastic footprint per patient refers to the absolute volume divided by patients reached.Total waste generated by Novo NordiskWaste collected by a certified waste management company and waste intended for collection. It is measured by weight receipts or other data from the waste management company, including all waste fractions and disposal methods. December data was estimated. Waste data for offices and affiliates outside Denmark are extrapolated based on headcount data available for their Danish counterparts. All waste subcategories are split between hazardous and non-hazardous waste according to the EUâs Waste Framework Directive. Radioactive waste is reported separately and not included in the total. Hazardous and non-hazardous waste diverted from disposal due to preparation for reuse, recycling or other recovery operationsAll waste directed for reuse without any further processing and waste directed for recycling or any other recovery operation, excluding energy recovery by incineration. We estimate the preparation for reuse to be negligible.Hazardous and non-hazardous waste directed to disposal by incineration, landfill and other disposal operations All waste directed to disposal by incineration, both with and without energy recovery, and by landfill at designated landfill sites. Percentage of non-recycled wasteShare of all waste directed to disposal out of total waste. Total amount of radioactive waste Total amount of waste materials that contain radioactive substances generated at Novo Nordisk and transferred to a radioactive waste management facility. We handle radioactive waste in compliance with applicable regulations.2.3 PollutionNovo Nordisk relies on both biological processes and chemicals to produce medicines, devices and packaging materials. As a pharmaceutical company, chemical substances have particular relevance to our business, and we comply with and report in accordance with all relevant regulations to prevent and control all types of pollution.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainChemicals affecting human health or ecosystems⢠Upstream ⢠Own operations⢠DownstreamWhile chemicals are an essential component in the production of medicines, some Substances of Concern (SCs) and Substances of Very High Concern 1(SVHCs) can potentially have a negative impact on health or the environment. Material impacts related to SCs and SVHCs concern both substances procured or used in production, and substances that leave our facilities in products or as emissions (see illustration on the right hand side). Processes to identify impacts, risks and opportunitiesTo identify pollution-related impacts, Novo Nordisk conducts annual environmental assessments at all production sites, covering air emissions, waste, noise, water withdrawal and water discharge, soil and ground water. We screen for harmful chemicals, including those covered by relevant regulations such as REACH during the product development process, and we use the EU Commissionâs definition of Most Harmful Substances when defining chemicals in scope.Negative impactPositive impact Opportunity RiskNegative impact Opportunity Risk Positive impact 1. SVHCs are chemicals that have serious irreversible effects on human health or the environment, in accordance with REACH. SCs are additional chemicals that have harmful effects.Substances of concern and very high concernPolicies Novo Nordiskâs environmental policy states our commitment to handling chemicals safely and striving to avoid the use of harmful chemicals, when developing or designing new products and processes. Our screening of harmful chemicals applies to both in-house and outsourced product development processes. For treatments already on the market, we strive to minimise the use of these chemicals and substitute them where possible.All of Novo Nordiskâs production facilities are ISO 14001 certified for environmentalmanagement and thus mitigate, control, and prevent negative environmental impacts, including pollution-related incidents and emergency situations. We reusechemicals where possible and ensure the best possible handling of hazardous waste and emissions. We also ensure compliance with the terms of the environmental permit for each production site. In case of breaches of regulatory terms, we register an environmental non-conformity, investigate, and implement corrective actions. ActionsWe work with several innovation projects in both our own and outsourced production processes to reduce the environmental impacts of our products on an ongoing basis, as described in the table below.PerformanceWe continuously track our use of chemicals through various internal KPIs and environmental assessments to ensure that we mitigate negative impacts on the environment or human health. A total of 2,304 tonnes of SCs and SVHCs were procured in 2024. Most of their use is linked to solvents used in the production of our API. We are seeking to reduce the use of these chemicals through substitution initiatives or purification for reuse, as described in the key action below. During the production process, almost all of SCs and SVHCs are collected as waste and handled safely in accordance with our policies and any relevant regulations.Novo NordiskEmissions to air and waterProcured substances Products / part of productsof (very high) concernWasteThe remaining substances, leaving Novo Nordisk in the form of emissions or as part of products, were estimated to be 11 tonnes of SCs and SVHCs during 2024. SCs leaving our facilities as part of our products make up 5 tonnes, and originate primarily from one substance used as an excipient in extremely low concentrations to preserve our medicines. The remaining SCs and SVHCs leave our facilities as emissions to air and water. In 2024, this amounted to approximately 5 tonnes of SCs and 1 tonne of SVHCs, primarily linked to the production of API. The reported volumes of SCs and SVHCs leaving our facilities are within regulatory limits.In addition to the disclosures above, we also report in accordance with the European Pollutant Release and Transfer Register.Key action to addresschemical pollution Reducing chemicals in production and medicinesDescription and year of completionRecurring action to minimise the use of specific chemicals in production processes through substitution or purification for reuse, and to optimise efficacy of medicines with lower chemical use.Scope of actionIn-house and outsourced production processesTarget in placeNo Overall progress in 2024 and how we track effectiveness⢠The use of relevant chemicals is tracked through environmental assessments at production sites and during product design and development processes to monitor effectiveness.Substances of concern Substances of very high concern22.3.1 Substances of Concern and Substances of Very High ConcernUnit 2024 2023 2022 2024 2023 2022Substances procured Tonnes 445 â â 1,859 â â⢠Human health hazard Tonnes 355 â â N/A â â⢠Environmental hazard Tonnes 111 â â N/A â â⢠Physical hazard Tonnes 0 â â N/A â âSubstances leaving facilities as emissions, as products, or as part of products Tonnes 10 â â 1 â âSubstances leaving facilities as emissions Tonnes 5 â â 1 â â⢠Human health hazard Tonnes 5 â â N/A â â⢠Environmental hazard Tonnes 0 â â N/A â â⢠Physical hazard Tonnes 0 â â N/A â âSubstances leaving facilities as products, or part of products Tonnes 5 â â 0.003 â â⢠Human health hazard Tonnes 5 â â N/A â â⢠Environmental hazard Tonnes 0 â â N/A â â⢠Physical hazard Tonnes 0 â â N/A â â2. If a material belongs to more than one main hazard class, the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total.ACCOUNTING POLICIESThe figures reported in Table 2.3.1 are manually calculated from the available dataand are subject to significant uncertainty. The weight of substances is calculated according to their concentration in the material. If information on concentration is not available, the assumption is that 100% of the material consists of substance(s) in scope. Consequently, certain metrics might be overestimated. The scoping of the materials included in the calculations may not be exhaustive. Main hazard classes (human health, environmental and physical)Defined by chemical subject matter experts, based on the specific hazards they present and includes following hazard class codes: Human health hazard (hazard class code H3xx or EUH3xx), environmental hazard (hazard class code H4xx or EUH4xx or EUH059) and physical hazard (hazard class code H2xx or EUH2xx). If a material belongs to more than one main hazard class (human health and environmental hazard) the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total. Main hazard classes are not applicable to SVHCs.Total weight of substances of concern/ substances of very high concernComprise the total weight of substances procured into production, categorised into main hazard classes. Data sources include receipts of materials and purchase orders mapped against a chemical database indicating hazard class.Amount of substances of concern and substances of very high concern that leave facilities as emissionsTotal weight of SCs and SVHCs that leave production sites as emissions to air or water, split into main hazard classes. The estimated volumes of substances are based on available data for our API production and estimated for Chemistry,Manufacturing and Control (CMC) processes. Laboratories were deemed immaterial and are not in scope. Novo Nordisk Pharmatech A/S will be included from 2025.Amount of substances of concern that leave facilities as products or part of productsTotal weight of SCs and SVHCs that leave Novo Nordisk as products or part of products split into main hazard classes. Products or parts of products are defined as either excipients or devices. Data sources include production data (with final product quantities), bills of materials and purchase orders mapped against a chemical database indicating hazard class.2.4 WaterWater is an essential natural resource in the manufacturing of Novo Nordiskâs pharmaceutical products and a key input to many commodities in our supply chain. Hence, water management is key to both our own operations and to our value chain, where we as part of our new nature roadmap, further described on page 68, are expanding actions and engaging suppliers to mitigate our negative impacts on water resources.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainAvailability and deterioration of water resources⢠Upstream ⢠Own operations⢠DownstreamNegative impacts on water availability occur when we source water for production purposes, especially in water-stressed areas, and at the end-stage of production, when water is discharged to water treatment plants, which can impact water quality. Resilience is assessed as part of our nature and biodiversity efforts and is further described in the transition plan in section 2.5 'Biodiversity and ecosystems' on page 68.Processes to identify impacts, risks and opportunitiesTo assess water-related impacts, risks, and opportunities, we conduct screenings of our production sites for areas of water stress and risk using the tool Aqueduct 4.0 from the World Resource Institute (WRI). As part of our engagement in water stewardship, in 2024 we conducted stakeholder engagements with water management authorities and other industrial water users at our sites in Montes Claros, Brazil, and Hillerød, Denmark, and at our largest API production sites: Clayton, US, and Kalundborg, Denmark. Water withdrawal, consumption and dischargePolicies Novo Nordiskâs environmental policy addresses water management and sets outour ambition to design less water-intensive processes by reusing and recycling water. We treat production-related water discharge onsite and/or offsite and avoid water pollution by discharging water in accordance with local regulations, and in case of any breaches, we take corrective actions.In addition, our environmental policy also addresses our special focus on water withdrawal in areas of high water-stress or risk, both at our own sites and with suppliers of key commodities, for example through our water withdrawal savings programme and planned efforts to engage priority suppliersThe policy also addresses our support of water stewardship principles and collective actions in water basins that are under pressure, for example in our current efforts to establish district cooling in Kalundborg and planned efforts to enhance water quantity and quality as detailed in the key actions below.Key action to address water Water withdrawal savings programmeEngaging priority suppliersTaking actions outsideof sitesSaving water throughthe establishment of district cooling in KalundborgDoubling wastewater treatment capacity in KalundborgDescription and year of completionEfficiency projects at production sites in scope, including optimisation of water use, creating systems for single and multiple reuse and recycling. We systematically map opportunities for water savings to create detailed savings plans, and the programme is planned to run until 2033.Engaging priority suppliers on their water impacts through a capability-building programme. Planned for 2025-2033Enhancing water quantity and quality outside of our sites, including replenishing water. Planned for 2025-2033.Establishment of district cooling at our largest production site in Kalundborg, Denmark, which accounts for half of our total water withdrawals, including phasing out the use of water from Lake Tissø. Industrial collaboration with the Kalundborg Symbiosis,Kalundborg Utility, and Novonesis. Expected completion of construction during 2026.Expansion of on-site wastewater treatment operated by Novonesis, doubling the industrial wastewater and biomass treatment capacity. Energy is recovered in the treatment process as part of the Kalundborg Symbiosis. To be completed in 2026.Scope of actionProduction sites with high water withdrawals and/or high water-risk/stress areaKey suppliers to be identifiedUpstream value chain Production site inKalundborg, DenmarkProduction site inKalundborg, DenmarkTarget in placeNo No No No No Overall progress in 2024 and how we track effectiveness⢠To track the effectiveness, sites in scope forecast expected water withdrawals and implement water savings initiatives. Water savings are registered per initiative via an internal dashboard.3⢠Total water savings in 2024 amounted to 105,600 m,3of which 51,000 m was in areas of high water-stress and/or water risk.⢠Action to be initiated in 2025, when processes for tracking effectiveness will be established.⢠Action to be initiated in 2025, when processes for tracking effectiveness will be established.⢠Progressed with the construction process, which is expected to be finalised during 2026, with surrounding factories connected from 2026 onwards.⢠Expected annual water withdrawal savings upon 3completion estimated at 400,000 m.⢠Project launched and construction has started.ActionsWe implemented and planned several actions in 2024 to mitigate our impacts on water, as part of our Circular for Zero strategy and our new nature roadmap, described further on page 68. Key actions to mitigate negative impacts on water are listed in the table on this page.PerformanceWe have not set external targets on water, but systematically track water withdrawals and water savings as part of our water withdrawal savings programme, as described in the table of key actions. In 2024, we experienced an increase in water withdrawal of 26% compared to 2023 due to our growth. Most of the increase is due to increased API production, as well as water used in expansion and construction projects. In 2024, the organisational scope of water withdrawal expanded to also include water withdrawals for offices and research facilities outside of Denmark, which increased the total water withdrawal by further 3%.Most of water drawn into the boundaries of Novo Nordisk is used for cooling and the fermentation process, and is subsequently discharged, making the actual water consumption relatively low. The largest share of water consumed comes from evaporation, water waste (sludge) and water in our products. We 3estimate that, in 2024, over 400 thousand m of water were reused or recycled at our production facilities.Production sites in China (Tianjin), US (Clayton and Durham), Iran (Tehran) and Algeria (Blida) are located in areas with high or extremely high water-stress and/or water risk. These sites account for approximately 23% of the total water withdrawal, with the biggest withdrawal occurring in the US and China. 2.4.1 Water consumption Unit 2024 2023 20223Total water consumption 1,000 m630 â â13⢠Water withdrawal1,000 m 5,213 4,150 3,9183⢠Water discharge1,000 m 4,583 ââTotal water consumption in areas at water 31,000 m191 â ârisk, including areas of high water stress3⢠Water withdrawal 1,000 m 1,217 â â3Total water recycled and reused 1,000 m416 â â3Water intensity ratio m/mDKK2.17â â1. Water withdrawal was previously reported as 'Water consumption'.ACCOUNTING POLICIESWater withdrawal Includes all types of water such as drinking water, industrial water, steam, rain water and water from remediation wells and rainwater. Data is based on meter readings and invoices. Data for offices and affiliates outside Denmark are extrapolated based on data available for their Danish counterparts (approximately 97% of the total is based on primary data). Water discharge Includes discharge of process- and sanitary water and discharge from storm water to outside Novo Nordiskâs boundaries, and water discharge used for irrigation. For offices where discharge data are not available, it has been assumed that water discharge equals water withdrawal. Water consumption Water drawn into Novo Nordiskâs boundaries but not discharged, calculated as the balance between total water withdrawal and total water discharge.Total water consumed in areas at water risk, including areas of high-water stressTotal water consumed by sites located in areas at water risk, including areas of high water stress. The identification of production sites in scope is performed using the Aqueduct 4.0 Water Risk Atlas tool provided by the World Resource Institute using two indicators: baseline water stress and overall water risk. 'Highmeans high or extremely high ratings in Aqueduct 4.0. The data reported are based on primary data.Total water recycled and reusedTotal quantity of water and water discharge (treated or untreated) that has been used more than once at the production sites before being discharged. The volume is estimated based on key indicators for specific water treatment equipment and technologies available at the sites. This includes steam condensate returned to steam generator, reverse osmosis water treatment, and water discharge from water treatment for irrigation. The metric is estimated with a conservative approach.Water intensity ratio Total water consumption (as outlined above) per DKK million in net revenue, defined as total net sales generated by Novo Nordisk.2.5 Biodiversity and ecosystemsWe rely on natural resources in our production of pharmaceutical products, primarily agricultural (glucose), forestry (paper), fossil-based (plastic) commodities, and water. In 2024, we developed a new nature roadmap to accelerate our efforts to address these impacts.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainReliance on natural resources and ecosystem services⢠Upstream ⢠Own operationsOur resource use in production processes leads to negative impacts on nature. Such impacts can also occur due to land-use change when establishing new production sites impacting local ecosystems and contributing to the loss of natural habitats. Along our value chain, the sourcing of raw materials that require fresh-water or land-use change also have impacts on nature, especially agricultural production or deforestation for wood-based materials, where pollution, for example from pesticides used for agricultural purposes, can exacerbate negative impacts.Identified IRO Category Value chainReliance on vulnerable species in research⢠Upstream⢠Own operationsNovo Nordisk's material impact on vulnerable species includes our reliance on horseshoe crab blood for endotoxin testing, which is required to ensure the safety of our medicines. Extraction of horseshoe crab blood can harm survival rates of the animals even though they are released back into their natural habitats. We no longer use products from endangered horseshoe crab species, and are working to phase out the use of lysate from vulnerable horseshoe crab species. Processes to identify impacts, risks and opportunitiesTo assess Novo Nordisk's impacts on biodiversity and ecosystems, we undertook an assessment aligned with the Science Based Targets Network (SBTN) methodology, covering our direct operations and upstream value chain and using primary activity data and lifecycle assessment (LCA) databases, along with data on the state of nature. Furthermore, we screened our value chain for high-impact commodities that cause an increased pressure on nature.Dependencies on nature were assessed across our value chain using the ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) tool to evaluate relevant sub-industries, based on the areas most likely to disrupt Novo Nordisk in terms of raw material inputs, production processes, and testing. Physical and transition risks were assessed separately using the World Wildlife Fund Biodiversity Risk Filter and through a qualitative scenario analysis. Systemic risks were not considered, and consultations with affected communities were not conducted. As we have not yet been able to develop a methodology to assess whether our operational sites are having negative impacts on biodiversity sensitive areas, we do not currently have mitigation measures in place.Biodiversity loss, conditions of and dependencies on ecosystems and state of speciesPoliciesNovo Nordisk's environmental policy is aligned with our nature roadmap and it covers the key drivers of biodiversity loss such as water- and land-use, over-exploitation, pollution, and climate change, to mitigate material nature-related impacts. Its scope covers all our owned, leased, or managed operational sites, including those near biodiversity sensitive areas.The policy sets out our commitment to protecting and restoring nature and biodiversity, as well as our ambition to work with suppliers to create solutions with less impact on water-, forest-, and land-use, for example, through regenerative agriculture. We will also work with partners on restoration activities beyond our value chain. As such, the policy relates to both our impacts and dependencies on nature, as described in this section. The policy does not address social consequences of biodiversity and ecosystems-related impacts. In addition to the provisions in our environmental policy, Novo Nordisk adheres to all local regulations related to nature and biodiversity in the establishment of new sites and in our production sourcing and processes.Actions and transition plan for nature Novo Nordisk's nature roadmap, formalised in 2024, has an overarching aspiration to halt the loss of nature in our value chain by 2033, and become nature positive by 2045. This will be achieved by reducing our impact on land, water, and biodiversity, while driving positive impacts through restoration and transformative actions. In pursuing our ambition, we seek to mitigate the risks nature loss poses to our business and drive action for nature in line with global policy frameworks, including the Kunming-Montreal Biodiversity Framework and the EU Biodiversity Strategy for 2030. The nature roadmap has been approved by Executive Management and Board of Directors. The key actionsto address our impacts and deliver on our nature roadmap are outlined in the table to the right, including actions incorporating nature-based solutions, such as restoration projects. Local and indigenous knowledge will be incorporated into the development of restoration projects where appropriate, and we do not use biodiversity offsets as part of our nature roadmap.To inform the development of our nature roadmap in 2024, we conducted a high-level resilience analysis of the exposure of our current business model to ecosystem-related risks. The analysis considered one scenario where we meet our nature roadmap ambitions and one in which we do not. The results indicated that implementation of the roadmap could decrease Novo Nordiskâs exposure to nature-related risks related to raw material shortage and emergingdeforestation regulation and highlighted the need for continued focus on watermanagement. In conducting the analysis, it was assumed that high nature degradation would continue along the current trajectory towards 2030 and 2050. The scope included the upstream value chain of strategically significant raw materials in selected geographies, water withdrawal at key sites in our own operations, and chemicals in water discharge in the downstream value chain. External stakeholders were not involved in the analysis.Performance As part of our nature roadmap, we are continuously working to understand and measure our impacts and dependencies, and will continue this effort as we begin implementing the roadmap in 2025, also establishing processes to track the effectiveness of our actions.Key action to address biodiversity and ecosystems Reduce impact on waterReduce impact on land by addressing deforestation, soil degradation and pollution in supply chainReduce impact on biodiversityRestoration projects Transformation Minimise and phase outthe use of biological products from vulnerable and endangered speciesDescription and year of completionReduced impact on water through water withdrawal savings at production sites in scope, together with other actions as detailed in section 2.4 'Water' on page 66.Avoid degradation of land in our supply chain by ensuring a deforestation free paper and cardboard supply chain, and strive for all glucose to be sourced from regenerative agriculture.Restore biodiversity at key sites, ensuring positive impacts by 2033. Avoid impacts on endangered species.Initiate restoration projects near key sites by 2033. Develop a global restoration plan linked to our value chain by 2026 to become nature positive by 2045.Through transformative approaches, optimise and replace glucose in API production to bring our glucose land footprint close to zero by 2045.Minimise and phase out the use of horseshoe crab materials, Tachypleus amebocyte lysate, TAL, and Limulus amebocyte lysate, LAL. The use of lysate from the endangered Chinese horseshoe crab, TAL, has been phased out, and the remaining phase-out of LAL from the vulnerable American horseshoe crabis tentatively expected between 2025 and 2035, withthe majority of testing expected to be phased out by2027. The complete discontinuation depends on regulatory approvals of alternative testing methods.Scope of actionOwn operations and key suppliersSupply chainOwn production sitesOwn value chain and beyondOwn operationsOwn operations Target in placeNo NoNoOverall progress in 2024 and how we track effectiveness⢠Water withdrawals and water savings are tracked.⢠For more details, see section 2.4 'Water'.⢠Process to track effectiveness of supplier engagement to be established during roadmap implementation in 2025.⢠Novo Nordiskâs nature roadmap was endorsed in 2024 and will be implemented from 2025 onwards, during which processes to track effectiveness will be established.⢠Phase-out of TAL has been completed as of 2023.⢠Use of LAL in our research areas was discontinued in 2024, and we continue working to phase out use for remaining testing of samples. The recent acceptance by the European Pharmacopoeia and the USP Microbiology Expert Committee of the use of recombinant reagents for relevant testing marked an important milestone towards this goal.2.6 EU TaxonomyThe EU Taxonomy provides a classification system that defines which economic activities are environmentally sustainable, while meeting standards for human rights, anti-corruption, fair competition and taxation. Novo Nordisk welcomes the introduction of comparable sustainability definitions and is working to incorporate relevant EU Taxonomy criteria into our operations to support our sustainability ambitions.The Taxonomy-related disclosure process can be broken down into three major steps. ⢠The first step is a screening of potentially eligible economic activities (screeningin accordance with the technical annexes of the Climate Delegated Act: Annex 1on Climate change mitigation and Annex 2 on Climate change adaptation and ascreening of the Environmental Delegated Act: Annex I on Sustainable use and protection of water and marine resources, Annex II on Transition to a circular economy, Annex III on Pollution prevention and control and Annex IV on Protection and restoration of biodiversity and ecosystems), which results in an already shortened list.⢠In the next step, each of the economic activities are assessed against how Novo Nordisk performs the activity, considering a financial and strategic materiality. This is followed by the detailed assessment of the alignment of identified economic activities, comprising substantial contribution, 'Do No Significant Harm' (DNSH) and minimum safeguards. ⢠Finally, the KPIs required for Taxonomy reporting are extracted (see Novo Nordisk adjusted tabular overview on the next page and the detailed mandatory reporting templates in section 5, tables 4 a-c on pages 97-99). Taxonomy-eligibility Based on our annual review process and materiality considerations, the following economic activities defined in the EU Taxonomy have been identified as relevant to Novo Nordisk:⢠P1.2: Manufacture of medicinal products (environmental objective Pollution prevention and control) - relevant for the Turnover, CapEx and OpEx KPIs (eligibility).⢠CCM7.1: Construction of new buildings (environmental objective Climate change mitigation) - relevant for CapEx (eligibility and alignment).⢠CCM7.2: Renovation of existing buildings (environmental objective Climate change mitigation) - relevant for CapEx (eligibility).Taxonomy-alignment â Substantial contribution and 'Do No Significant Harm' (DNSH)Novo Nordisk has assessed the technical screening criteria for eligible economic activities deemed material and has conducted an internal analysis of the feasibility of Taxonomy-alignment. This leads to the following result for 2024: ⢠7.1 Construction of new buildings: An evaluation of the Climate Delegated Act Annex 1 on climate change mitigation has been conducted, leading to the conclusion that alignment of new building construction can be claimed following a positive gap analysis. A proportion of two major ongoing construction projects in Hillerød and Kalundborg, Denmark, have met the requirements of Taxonomy- alignment. These projects demonstrate compliance with a substantial number of the technical screening criteria for 2024. Certain criteria are yet to be fulfilled because the relevant construction phase has not been reached. We assume fulfilment of these on the basis of pre-calculations in the design phases, robust processes, and controls throughout the entire construction process. We thereby claim alignment based on the expectations that our construction continues to follow our plans. As part of Novo Nordisk's commitment to expanding production capacity in a sustainable way, future building projects will incorporate alignment criteria when feasible in the upcoming years.⢠7.2 Renovation of existing buildings: This economic activity represents the second phase in implementing Taxonomy-alignment within our construction and real estate activities. No alignment is reported for this activity in 2024.⢠1.2 Manufacture of medicinal products: We are also conducting an initial assessment of alignment criteria focused on our Danish manufacturing sites ®®for Ozempic and Wegovy for economic activity 1.2. We currently meet many of the criteria, such as using readily biodegradable ingredients in our medicinal products and managing emissions of pollutants to air, water, and soil. However, we have encountered challenges in obtaining evidence for, or addressing the practical aspects of, meeting some of the criteria, which will require further consideration in alignment with our Circular for Zero strategy.Taxonomy-alignment â Minimum safeguardsOperating as a responsible business is a core value for Novo Nordisk, including meeting the minimum safeguards defined in the EU Taxonomy through the following practices:⢠Commitment to respecting human rights across our value chain. Our human rights due diligence process is aligned with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises (see section 3.3 'Workers in the value chain' on page 89).⢠Strict prohibition of bribery and corruption, and adherence to relevant laws and industry codes. Our robust anti-corruption programme comprises internal audits, training for employees and business partners as well as due diligence around third-party representatives (see section 4.1 'Business conduct' on page 91).⢠Managing our tax affairs responsibly, while complying with both the letter and spirit of the law. We are committed to tax transparency and comply with applicable tax regulations.⢠Valuing fair competition and complying with laws governing relationships with suppliers, customers, and competitors. Employee awareness of competition laws is promoted, and all business practices are aligned with these regulations.1Novo Nordisk adjusted EU Taxonomy overview1(see section 5, tables 4 a-c for the mandatory reporting templates)Turnover CapExOpEx2024 2024 2024Environmental objective Economic activity (mDKK) (%) (mDKK) (%) (mDKK) (%)Total Turnover, CapEx, OpEx 290,403 100 57,720 100 39,933 100Taxonomy-non-eligible activities 0 0 18,698 32 38,014 95Climate change mitigation 7.1 Construction of new buildings 0 0 13,050 23 0 07.2 Renovation of existing buildings 0 0 2,336 4 0 0Pollution prevention and control 1.2 Manufacture of medicinal products 290,403 100 20,142 35 1,919 5Eligible not aligned 290,403 100 35,528 62 1,919 5Eligible and aligned7.1 Construction of new buildings (in Hillerød and Kalundborg, Denmark) 0 0 3,494 6 0 01. Excluding impact of Catalent acquisition. With the inclusion of Catalent, total CapEx would have been DKK 123,972 million, eligible not aligned CapEx 29% and eligible and aligned CapEx 3%.Contextual information about the KPIsIn 2024, no additional economic activities were added to the reporting scope and no changes were made to the data collection process. As a result of our Taxonomy screening process:⢠Turnover in 2024 was 100% Taxonomy-eligible, but 0% Taxonomy-aligned.⢠CapEx in 2024 was 68% Taxonomy-eligible (32% including Catalent), hereof6% eligible and aligned (3% including Catalent) under economic activity 7.1'Construction of new buildings'.⢠OpEx in 2024 was 5% Taxonomy-eligible, but 0% Taxonomy-aligned. We consider all Novo Nordiskâs turnover Taxonomy-eligible under economic activity 1.2. Taxonomy-eligible CapEx includes only CapEx directly associated with the manufacturing process or related to construction or renovation of buildings; intangible assets are therefore excluded. This is the main reason for reported Taxonomy-eligibility under economic activity 1.2 being less than 100%. Eligible CapEx mainly relates to the expansion of production capacity and additions to property, plant and equipment, as per note 3.2 'Property, plant and equipment' on page 115 in the Consolidated financial statements. Eligible OpEx includes R&D directly linked to the manufacturing processes. As a result, only R&D costs from Chemistry, Manufacturing and Control Development & Scaling (CMC) are counted as Taxonomy-eligible OpEx. Taxonomy reporting templates in accordance with Article 8 of Commission Delegated Regulation (EU) 2021/2178, as amended by the Taxonomy Environmental Delegated Act (Commission Delegated Regulation (EU) 2023/2486) can be found in section 5, tables 4 a-c.We do not carry out any activities relating to the generation of nuclear energy and fossil gas as per delegated regulation 2022/1214 and hence consider these economic activities not applicable. Novo Nordisk purchases fossil gas for own production processes (see section 2.1 'Climate change' for further details).Moreover, the EU Taxonomy Regulation and the related Delegated Acts contain formulations and terms that are still subject to considerable interpretation uncertainty and for which clarifications have not yet been published in every case. Due to the inherent risk that undefined legal terms can be interpreted differently, the legal compliance of the interpretation is subject to uncertainty (we refer to the section 'Forward-looking statements' on page 35 for further details).ACCOUNTING POLICIESThe Taxonomy KPIs include all fully consolidated companies of the Novo Nordisk Group. The CapEx resulting from the acquisition of Catalent in December 2024 (see section 1.2 âBasis for preparation of the Sustainability statementâ on page 49) is recognised accordingly in the Taxonomy tables in section 5 in order to reconcile this with the financial reporting.Total Turnover Total revenue from sale of goods, as defined under IFRS Accounting Standards (see note 2.1 'Net sales and rebates' on page 107 in the Consolidated financial statements). The turnover KPI is defined as Taxonomy-eligible turnover divided by total turnover. Capital expenditures (CapEx)Additions to fixed assets (including finance leases) and intangible assets. Additions resulting from business combinations are also included. Goodwill is not included in CapEx as it is not defined as an intangible asset in accordance with IAS 38. The CapEx KPI is defined as Taxonomy-eligible CapEx divided by total CapEx (see notes 3.1 'Intangible assets' on page 113 and 3.2 'Property, plant and equipment' on page 115 in the Consolidated financial statements). Operating expenses (OpEx)Direct non-capitalised costs that relate to R&D (see note 2.3 'Research and development costs' on page 110 in the Consolidated financial statements), building renovation, short-term leases, maintenance and repairs, and any other direct expenditures relating to the day-to-day servicing of property, plant and equipment. OpEx excludes amortisations and impairments. The OpEx KPI is defined as Taxonomy-eligible OpEx divided by total OpEx. None of our activities contribute to multiple environmental objectives, and so no disaggregation of KPIs is required. For the allocation of Turnover, CapEx and OpEx we have identified the relevant income, purchases and measures, and we have identified the primary related economic activities in the Climate Delegated Act. In this way, we ensure that no activity is double-counted. We are adjusting the R&D cost for amortisations. This is in order not to double count these costs, as the amortisation would have been part of CapEx in prior years. Moreover, there are no updates or restatements performed in 2024 for the information reported in 2023.3. Social13.1 Patient protection and quality of lifeNovo Nordisk's purpose is to drive change to defeat serious chronic diseases, and our efforts to make our innovative medicines accessible to patients throughout the world are associated with material impacts, risks and opportunities.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainImproving quality of life through medicines⢠DownstreamPotential new discoveries to serve patient needs⢠Own operations⢠DownstreamFrom discovery and clinical trials through to the production and sale of our innovative products, Novo Nordisk has material positive impacts on the lives of patients. With our investments to become a broader cardiometabolic-focused company, our efforts to further raise the innovation bar to tackle global health challenges creates potential new opportunities to help patients.Identified IRO Category Value chainReducing and preventing serious chronic diseases⢠DownstreamTo live up to our purpose, our social sustainability roadmap includes prevention efforts to help reduce the global health burden, with potential positive impacts when improving urban health for vulnerable communities. We especially focus on children to bend the obesity and diabetes curves, with the aim of having long-term health impacts and improving the resiliency of healthcare systems. Positive impact Negative impact Opportunity RiskNegative impactPositive impact Opportunity Risk1. Includes ESRS topics related to S4: âConsumers and end-usersâ and entity-specific topics such as prevention of serious chronic diseases and falsified medicines.Identified IRO Category Value chainHealth equity for vulnerable patients and in ⢠Own operationsclinical trials⢠DownstreamPotential reputational risks related to access efforts⢠Own operationsAs part of our social sustainability roadmap, Novo Nordisk has a positive impact when we help tackle growing health disparities, by strengthening capacity and increasing access to affordable care globally. We focus our efforts on vulnerable patients and children with serious chronic diseases, especially in low- and middle-income countries. In addition, we support accessibility through our clinical trials efforts. Global access and affordability challenges persist, which is considered a material reputational risk to Novo Nordisk. Due to different healthcare systems, medicines to which patients have access and the price they are charged vary significantly. We continue to collaborate with relevant stakeholders to ensure widespread, affordable access.Identified IRO Category Value chainSafe clinical trials and product quality and safety⢠Own operations⢠DownstreamProtection against falsified medicines⢠DownstreamEnsuring safe clinical trials and the efficacy, safety and optimal use of ourproducts is fundamental to everything we do. Patient safety is therefore a top priority, in order to mitigate any adverse health impacts and risks related to our products or clinical trials. In addition, we fight against falsified medicines related to our products in the market, in order to keep patients safe against any serious adverse health effects that may be caused by using illegally manufactured products.Identified IRO Category Value chainProtecting clinical trial and patient information⢠Own operations⢠DownstreamWe strive to protect clinical trial and patient information, ensuring patient privacy, responsible product communication and correct labelling of our medicines or devices, to mitigate any adverse health-related consequences for our patients. We consider insights from patients and patient organisations to be vital for the continued improvement of products, treatment and care, and adhere to applicable laws and human rights governing these interactions to limit any negative impacts.Identified IRO Category Value chainPotential reputational and regulatory risks⢠Own operationsAny failure to protect patients is not only a material negative impact, but also a risk to Novo Nordisk's business and reputation. We therefore do not compromise on product quality or patient safety.General process for patient engagement The exchange of information and insights with patients and patient organisations isvital for Novo Nordiskâs continued improvement of research, products, treatments, and care. We support patient empowerment, guided by our Patient Voice Strategy, and collaborate with patient organisations to improve prevention, treatment, and access to quality care for people living with serious chronic diseases. Our Patient Voice Strategy aims to directly benefit our trial participants and patients, while also informing our corporate and therapy area strategies. We are currently implementing our Patient Voice Strategy across all product development projects.Patient engagement takes place either directly with individual patients or with their caregivers, healthcare professionals, experts and relevant patient organisations as their legitimate representatives, in compliance with relevant laws and regulation. Engagement occurs before, during and after the launch of our products, with the frequency of engagement dependent on the stage of development and the type of treatment or product. Relevant patient populations are selected based on the insights needed and various channels are used for our patients to express thoughts and concerns, for example through patient advisory boards, workshops, and surveys.The engagement process is owned by our two chief patient officers, who have overall responsibility for ensuring that the needs and perspectives of patients and care partners are incorporated into our decision-making processes.Channels to raise patient safety concernsWe routinely monitor the safety and quality of all our products by reviewing safety data from clinical trials, reported side effects and quality complaints. By monitoring the quality and safety of our products, we can take timely and appropriate actions to safeguard patient safety and fulfil our reporting obligations to health authorities under relevant legislation.Patients can use our publicly available portals for any issues in relation to Novo Nordisk products, including product complaints or if they wish to report a side effect or falsified products. In addition, all affiliates have call centres operated in the local language where patients and healthcare professionals can get help in relation to a Novo Nordisk product. The channels are tracked by our Customer Complaints Department and Global Safety Department, which records, investigates and responds to customer complaints globally concerning the quality, labelling, durability, reliability, effectiveness, safety, performance or malfunction of Novo Nordiskâs products and reports these to health authorities in accordance with applicable legislation.Depending on the nature of the information received, there are strict timelines for when to escalate the matters for further investigation. All personal information related to the reporting of a product complaint or side effect is processed in accordance with data protection legislation.When necessary, we recall products affected by a safety or quality issue, update labels for marketed products, or communicate directly with affected patients, healthcare professionals or health authorities, informing them about product safety risks.InnovationPoliciesNovo Nordisk's purpose is to bring innovative medicines to help the millions of people worldwide living with serious chronic diseases. Our decades-long commitment to the development of GLP-1-based medications is not only reshaping diabetes and obesity management but also opening potential new avenues of treatment for cardiovascular, kidney, liver, and Alzheimer's diseases. Our innovations help improve quality of life for patients and at the same time, reduce the cost of hospitalisations for healthcare systems.To ensure that we impact society positively through our innovations, patients are at the centre of everything we do. Many of our policies therefore encompassour patient-related efforts. Our OneCode policy outlines the key requirements with respect to how we act across all our policies and standard operating procedures, including how we provide medicines in a responsible way, engage with all patients and adhere to high quality standards to advance the quality of care. Every year, all employees must confirm they have read and understood OneCode. We respect the human rights of patients, in accordance with our Human Rights Commitment further described in section 3.3 âWorkers in the value chainâ on page 88.Key action to addresssustainability-relatedinnovation Integration of sustainability in product developmentDescription and year of completionOngoing integration of sustainability in product development and product-related governance. Theframework assesses the social and environmental profile across the product's lifecycle to support development decisions and identify areas of improvement across product portfolio.Scope of action40+ products, including R&D pipeline and marketed productsTarget in placeNo Overall progress in 2024 and how we track effectiveness ⢠Piloted in five products across five different product development stages and five different therapy areas to test the robustness and applicability of the framework.⢠Rolled out the framework for +80% of the products in scope and will continue the implementation in 2025.Policy OneCodePurpose Guide on how to act as a company and as individualsScope Everyone employed by or working on behalf of Novo NordiskMost senior level Executive Managementaccountable Availability Externally available: OneCodeApplicability across ⢠Patient protection and quality of life, page 71Sustainability statement⢠Own workforce, page 80⢠Business conduct, page 90Supporting policy ⢠Position papers (Access to diabetes care and documentationmedicine pricing, clinical trials ethics, falsified medicines)⢠Principles (Data and Al ethics, processing of personal data)⢠Standard operating procedureActionsFor an overview of opportunities to accelerate healthcare innovation across Obesity, Diabetes, Rare Diseases and Cardiovascular & Emerging Therapy Areas, see section 'Innovation and therapeutic focus' on page 17. The action table provides an overview of other, sustainability-linked innovation efforts. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Prevention of serious chronic diseasesPoliciesNovo Nordisk invests in primary prevention of serious chronic diseases, with a focus on early prevention in childhood and targeting vulnerable populations such as socially disadvantaged communities. As a gateway to other chronic diseases, we have a specific focus on prevention of obesity.While we do not have a formal policy related to prevention, we have integrated our prevention activities into our therapy area strategies, as part of our social responsibility.ActionsTo implement our social responsibility within primary prevention, we take a multi-level approach through partnerships, working in urban environments to address issues such as nutrition, education and physical activity. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Sustainability-related costs are integrated in our ongoing business. In addition weset aside further dedicated funding across our social sustainability roadmaps related to both prevention and access to deliver on our global health equity ambitions (see also next section). Combined, we have further committed DKK 1.3 billion in investments in 2024 and 2025, excluding donations and other contributions that we report on in table 3.1.3. We will continuously assess needed investments as part of our financial planning processes. Extended valueis also created through grants to health, sustainability and the life science ecosystem, via our unique ownership structure, by the Novo Nordisk Foundation, our majority shareholder through Novo Holdings A/S.Social inclusion of patientsACCESS TO MEDICINESPoliciesHealth inequity is a global challenge, with overburdened healthcare systemsfacing growing pressure to deliver quality care while managing costs, disproportionately affecting people in resource-poor settings. To help drive positive impacts for our patients, Novo Nordisk has a commitment to help improve patient access and affordability. Our publicly available position papers further detail how we work with our social responsibility.Key actions to address prevention Partnership with UNICEFCities for Better Health Transformational Prevention Unit (TPU)Description and year of completionPartnership with UNICEF to prevent childhood overweight and obesity by building healthy environments that enable and empower children to eat well and be active. Partnership runs until 2026.Global network of prevention partnerships at city level, addressing three core challenges to drive better health in cities: healthy food, physical activity and sustainable financing models to ensure ongoingfunding.Develop scientific and scalable commercial solutionsthat predict and pre-empt obesity and its consequences for those at greatest risk. Established in 2023, the TPU is committed to building multi-sector partnerships with the ambition to support overall prevention efforts with substantial societal value, including socially disadvantaged groups.Scope of actionPrimary focus is on Brazil, Colombia, Mexico,and Indonesia51 cities across the worldIndividuals globally with higher risk of obesityTarget in placeNo No No Overall progress in 2024 and how we track effectiveness ⢠Roll-out of programmatic activities by UNICEF, for example strengthening nutrition education in schools and promoting use of food labelling.⢠UNICEF evaluates effectiveness against KPIs covering both indirect and direct impacts of the programmatic activities and report these in a publicly available report.⢠In 2024, a new childhood obesity prevention initiative, The Childhood Obesity Prevention Initiative (COPI), was launched in six cities across Brazil, Canada, France, Japan, South Africa and Spain to accelerate the prevention of childhood obesity in disadvantaged urban communities. ⢠In addition, 15 affiliates received technical and financial support to start local prevention initiatives.⢠A monitoring and evaluation framework is used to assess improved health-related outcomes.⢠Combining scientific insights with clinical, as well as public health data, with the aim to develop tailored and targeted interventions that meet specific individual and societal needs.⢠The tailored approach aims to enable earlier and more accessible prediction of health and disease, improving patient outcomes and minimising unnecessary treatments and reducing healthcare costs.Our position on access to diabetes care advocates for equal rights and accessibility to healthcare for all, as stated in the UN Universal Declaration of Human Rights. Theposition outlines our commitment to overcoming the barriers to effective diabetes care in low- and middle-income countries, including limited healthcare capacity andunreliable supply of medicine and equipment.Our position on medicine pricing outlines how pricing should reflect the medicine's value to patients, society and the healthcare system. This includes multiple factors such as the medical need the product meets for clinicians and patients and how the clinical profile improves the patients' short- and long-term health outcomes and quality of life. Other factors include contracting, pricing and reimbursement system of a given country. Each country has its own healthcare system, which can provide patients with different medicines at different costs. We acknowledge global affordability challenges, including in high income countries, and collaborate with policymakers and health authorities to help develop solutions to ensure affordable access for all patients.Actions In support of our position statements, several action plans are underway, as outlined in the table, in order to overcome barriers to effective care for vulnerable patients, including collaborating with external partners to improve access and affordability, enhancing supply chains and improve healthcare capacity. In the US, Novo Nordisk provides rebates and sales discounts to insurance companies and other payers to secure coverage for commercially and government-insured patients. For vulnerable patient populations, we offer low-cost or no-cost programmes. Unless otherwise indicated, actions are considered recurring. Across all actions, patients reached is considered a key performance indicator to ensure progress and effectiveness of our efforts.Key actions to address access to medicines Ringfenced volumes ®WegovyAccess to Insulin Commitment®Changing Diabetesin ChildreniCARE business model Human Thermal Solution(HITS)Access Innovation IncubatorCollaboration with WorldDiabetes FoundationPartnering for Change programmeAffordability programmes in the USDescription and year of completion®A proportion of Wegovy volumes in each launch market is ringfenced for access pathways such as public reimbursement, public institution purchase or other patient access and support programmes. The focus is to improve health equity and provide affordable care.A ceiling price of USD 3 per vial in low- and middle-income countries around the world and USD 2 per vial for organisations providing relief in humanitarian settings.Public-private partnership founded in 2009 to provide diabetes care to children and youth with type 1 diabetes living in low and middle-income countries. This includes free life-saving medicine,blood glucose monitoring equipment and medical supplies for young people under the age of 25Improve access to diabetes care to vulnerable populations. Implementation is integrated in affiliates' business strategies and targets through four main building blocks of health equity focused diabetes management: capacity, affordability, reach, and empowerment.®New flexible storage options for two Novo Nordisk human insulin products: Actrapid and ®Insulatard, making Novo Nordisk the first insulin manufacturer to introduce flexible storage options for people with diabetes in settings where refrigeration is a challenge.Identification of new and innovative solutions to support people with diabetes. Solutions include a global partnership with MedtronicLABS to scale a digital patient pathway for diabetes management in three African countries. Our Senselet partnership in Ethiopia strengthens supplychain capacity through higher education and on-the-job training.Donations to the independent and non-profit foundation, World Diabetes Foundation (WDF), to improve diabetes care by strengthening national health systems as well as primary prevention.Public-private knowledge-partnership between the International Committee of the Red Cross, London School of Hygiene & Tropical Medicine and the Danish Red Cross to address the growingneed for chronic disease treatment for people in humanitarian crisis areas.Creating comprehensive, affordable patient access by focusing our efforts on key levers:⢠Ensure affordable access to Novo Nordisk products to address challenges within the complex US healthcare system.⢠Increase product access among low-income population and/or individuals with disabilities through Medicaid.⢠Continue to offer programmes to maintain insulin affordability. ⢠Support vulnerable patient populations with free products across Diabetes and Rare Disease portfolios through Novo Nordiskâs patient assistance programmes.Scope of actionPeople with high medicalneed and low socioeconomic status77 low- and middle-income countries30 countries across Africa, Middle East, Asia and South America49 countries in Sub-Saharan Africa, and IndonesiaAll countries where ®Actrapid and Insulatardare launchedGhana, Kenya, Rwanda, EthiopiaLow and middle-income countriesLebanon and Iraq United States Target in placeNo No Yes No No No No NoNoOverall progress in 2024 and how we track effectiveness⢠Seven countries have agreements in place for access pathways such as public reimbursement, individual reimbursement or private insurance: UK, Japan, Switzerland, Qatar, Iceland, Norway, and Canada.⢠The patients reached through the Commitment are a part of the overall metric on vulnerable patients with diabetes reached through Novo Nordisk Diabetes care products in 2024.®⢠An accumulate 64,743 children and youth have been reached through Changing Diabetesin Children.⢠Patient education and healthcare capacity-building supported across more than 500 clinics.⢠Expansion of iCARE business model to Indonesia.⢠Served 433 thousand people with diabetes with insulin and trained 3,778 healthcare professionals through capacity building programmes through partnerships.⢠We assess effectiveness together with our partners.⢠38 countries have received approvals of label update. ®®⢠Expanding to all countries where Actrapid and Insulatard are launched depends on country approvals.⢠To date, the MedtronicLABS partnership has supported the enrolment of approximately 22,380 patients across 27 reference centres in three African countries. ⢠To date, Senselet has supported more than 1,000 front-line workers and 900 academics to receive training in healthcare supply chain management.⢠From 2025 onwards, these initiatives will be transitioned and integrated into the iCARE business model to ensure alignment with local and regional strategies and activities.⢠In 2024, donations to World Diabetes Foundation (WDF) reached DKK 120 million. ⢠11 peer-reviewed research publications, informing humanitarian efforts. ⢠Support handbook with guidance to patients in times of crises where continuity in care is disrupted.⢠The partnership is ending in 2024 but the Red Cross is staying on the ground despite the escalating crises in Lebanon. New commitment is in development.®®⢠In 2024, 80% of US patients with insurance coverage for Ozempic or Wegovy paid USD 25 or less for each prescription, and almost 90% of US patients paid USD 50 or less.®⢠Substantially increased access to Wegovy for Medicaid eligible patients with lower incomes and/®or disabilities, which now accounts for 10% of Novo Nordiskâs US Wegovy sales. ⢠Upheld 5+ year commitment to provide diverse insulin affordability support options, including MyInsulinRx⢠programme, unbranded biologic and human insulin treatment options. ⢠Continued commitment of long-standing patient assistance programme to support eligible patients.⢠Visit novocare.com for more information on our affordability programmes.PerformancePerformance on patients reachedTo track our impact worldwide we monitor the number of patients reached with Novo Nordisk's Diabetes and Obesity care products. The total number of patients treated with our Diabetes products increased 6% from 40.5 million in 2023 to 43 million in 2024. The development was primarily driven by the increase in Diabetes GLP-1-based products. We also increased the number of patients reached with Obesity treatments from 1.1 million in 2023 to 2.2 million ®in 2024. The 100% increase was primarily driven by the launch of Wegovy in +10 further countries in 2024. In addition to acquiring production sites in 2024, we are currently expanding and expect to see the effect of this on the number of patients reached in the future.Moreover, in 2024 we applied a new methodology to the number of vulnerable patients reached with Novo Nordisk's Diabetes care products. Due to different methodologies applied, vulnerable patients reached with Diabetes care products are not fully to be considered a portion of overall patients reached. In 2024, the number of vulnerable patients treated with our Diabetes care products decreased 5% from 8.8 million in 2023 to 8.4 million in 2024. This decrease was driven by fewer vulnerable patients reached through human insulin tender sales and access and affordability initiatives.®Performance on children reached through Changing Diabetes in Children ®To track progress on our programme Changing Diabetes in Children (CDiC), we have a target to reach 100,000 children and young people living with type 1 diabetes by 2030, starting from the inception of the programme in 2009. By the end of 2024, a total number of 64,743 children were reached. The countries in scope that contribute to reaching the target are the 30 partner countries of CDiC. The target was set by using international estimations, from the International Diabetes Federation (IDF), of number of children living with type 1 diabetes in low and middle-income countries. As part of the partnership agreements with local implementing partners, project milestones are set with the aim to improve diabetes care. The progress to reach the target is monitored quarterly and through annual reports received from local implementing partners.Performance on donationsWe have slightly increased our donations and other contributions to the World Diabetes Foundation in accordance with the donation agreement. With regards to the Novo Nordisk Haemophilia Foundation, we have increased our donation from DKK 19 million in 2023 to DKK 26 million in 2024 to support ongoing projects. 3.1.1 Patients reached with Novo Nordisk's products Unit 2024 2023 2022Patients reached with Novo Nordisk's Diabetes and Obesity Number in care productsmillions 45.2 41.6 36.9Patients reached with Novo Nordisk's Number in Diabetes care products millions 43.0 40.5 36.3Patients reached with Novo Nordisk's Number in Obesity care products millions 2.2 1.1 0.6Vulnerable patients reached with Number in 1Diabetes care productsmillions 8.4 8.8 â 1. 2023 figure for Vulnerable patients reached with Diabetes care products has been restated from 6.7 millions.®3.1.2 Changing Diabetes in children Unit 2024 2023 2022Children reached through the ®Changing Diabetes in children programme Number 64,743 52,249 41,033 2030 target Number 100,0003.1.3. Donations and other contributions Unit 2024 2023 2022Total donations and other contributions mDKK 146 138 126World Diabetes Foundation (WDF) mDKK 120 119 93Novo Nordisk Haemophilia Foundation (NNHF) mDKK 26 19 33ACCOUNTING POLICIES Patients reached with Novo Nordisk's Diabetes and Obesity care productsEstimated by dividing Novo Nordisk's annual sales, samples and donations volume by the annual usage dose per patient for each product class, as defined by the WHO (for Diabetes) or in accordance with the dose strength of the product (for Obesity). Devices are excluded. Methodology has been changed compared to previous years as samples and donations have been added in 2024. The impact on the comparative figures is deemed immaterial and hence no restatement has been made. Vulnerable patients reached with Novo Nordisk's Diabetes care productsDefined as a patient who received Novo Nordisk Diabetes care products either through products sold under local affordability thresholds, based on World Bank data and local healthcare expenditures, or public tenders in low-, lower middle- or upper middle- income countries (LMICs) as defined by the World Bank, or through specific diabetes access and affordability programmes or humanitarian donations. Vulnerable patients are estimated by using two methods: firstly, reach of one vulnerable patient is defined as sales volume in LMICs corresponding to an annual drug usage dose per patient as defined by WHO through public tender sales, products sold under affordability thresholds, or humanitarian donations and for vulnerable patients reached in the US through products supplied in select programmes. Secondly, for US access and affordability programmes, reach of one vulnerable patients is defined at the time of enrolment based on patient programme reports. ®Children reached through the Changing Diabetes in Children programmeEstimated as the total accumulated number of children and youth enrolled since the initiation of the partnership in 2009. Children participating for multiple years are only included once in the year of enrolment. Children and youth are defined as 0-25 years old and living in poverty as defined by the World Bank.Donations and other contributionsThe monetary donations from Novo Nordisk to the World Diabetes Foundation (WDF) and the Novo Nordisk Haemophilia Foundation (NNHF) are recognised when the donation or contribution is paid out.ACCESS TO CLINICAL TRIALSPolicies In accordance with our OneCode policy, we believe health equity is central to the development of new treatments, as everyone should have access to medical products regardless of demographics, underlying diseases or social factors.We focus our efforts on promoting diversity, equity and inclusion (DE&I) in clinical trial conduct to ensure that scientific data are representative of the patient population and have internal procedures in place to support such efforts. We acknowledge that accomplishing this demands tailored solutions specific to each trial programme.ActionsTo further advance our health equity efforts in clinical trial conduct, we focus our efforts on implementing DE&I considerations and decentralised trial elements (DCT) as outlined in the table. Unless otherwise indicated, actions are considered recurring.Global efforts to enhance DE&I in clinical trials are led by an expert function in our Global Clinical operations area. Local efforts focusing on US activities are driven by our North American Organisation. However, DE&I efforts impact all functions acrossthe value chain involved in the design, planning and execution of clinical trials. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Key action to address access to clinical trialsPromotion of DE&I in clinical trialsIntegration of decentralised trials (DCT) elements Description and year of completionFramework for integrating DE&I in clinical trial planning and execution to ensure that clinical trial participants are representative of the patient population.Integrating DCT elements to help improve access to clinical trials, a more diverse pool of participantsand a higher retention rate, for example by allowing assessments to be conducted at patientsâ preferred location.Scope of actionGlobal trials on a fit-for-purpose basisGlobal trials on a fit-for-purpose basisTarget in placeNo No Overall progress in 2024 and how we track effectiveness ⢠Current focus has primarily been on US population.⢠Global actions include launch of a training programme in order to upskill relevant staff.⢠We participate in a public-private partnership (IHI READI) that aims to improve representation and inclusion in clinical research.⢠Overall effectiveness is assessed on an ongoing basis and we continuously assess how to optimise internal processes, including technology and data capture.⢠In 2024, over two thirds of our active phase 2-3 clinical trials included one or more DCT elements.⢠We actively engage with regulatory bodies, clinical research sites and patient advocacy groups to address the various barriers for implementing DCT elements in clinical studies.Patient safetyPRODUCT QUALITY AND SAFETYPoliciesEvery day, people rely on the quality and safety of our products. Various systems and standard operating procedures help us to safeguard this, including Novo Nordiskâs quality management system, which ensures we adhere to the highest quality standards and mitigate negative impacts and risks related to the safety of patients, for our authorised medical products and devices. Furthermore, our global pharmacovigilance system collates all safety information to monitor the safety of our products and devices and ensure that we meet all regulatory requirements to protect the safety of patients and clinical trial participants. The pharmacovigilance system has three key processes: 1) safety data collection, 2) data analysis and evaluation, and 3) routine reporting to health authorities and communication with relevant parties. The Global Head of Safety is responsible for the global pharmacovigilance system, ensuring that all relevant safety data reported to Novo Nordisk on investigational, authorised, and that marketed pharmaceutical products and medical devices are recorded, evaluated, and collated for surveillance and reporting.CLINICAL TRIAL SAFETYPoliciesAll Novo Nordiskâs clinical trials and clinical research activities are governed 2by national laws and international conventions as described in our publicly available position on clinical trials ethics and are integrated into our standard operating procedures to ensure safe global clinical research activities.Special consideration is given to vulnerable patient populations, including children and the elderly. If clinical research involves vulnerable patients, it is always evaluated whether the study should have an external Data Safety Monitoring Board to ensure independent safety review of the study. To ensure that our medicinal products and formulations are safe and effective for a paediatric population, we develop paediatric plans as required by the European Medicines Agency, the UK Medicines & Healthcare Products Regulatory Agency, and the FDA and Good Clinical Practice Guidelines. We conduct paediatric clinical trials with minimal disruption and interference with the childrenâs and their familiesâ daily lives.2. Including The Declaration of Helsinki, the International Conference on Harmonisation Guideline for Good Clinical Practice, Good Pharmacoepidemiology Practices, the Nuremberg Code, the UN Guiding Principles on Business and Human Rights, the Belmont Report and UNESCOâs Universal Declaration on Bioethics and Human Rights.Our internal, multidisciplinary Paediatric Expert Group offers guidance to aid such principles. Additionally, processes for seeking informed consent from a minor or their legally authorised representative must take place in accordance with local regulations and Novo Nordiskâs instructions.ActionsThe safety and quality of our products and clinical trials are prerequisites to Novo Nordisk's operating model. We routinely monitor the safety and quality by adhering to all relevant procedures and regulations. Patient safety is managed through our quality management and pharmacovigilance systems with the involvement of various internal functions. The pharmacovigilance system is owned and operated by the Global Patient Safety Department. There is close cooperation and alignment with the regions and affiliates, each responsible for managing matters related to local pharmacovigilance. Our quality management system is operated by the Global Quality organisation with the system applicable throughout the product development process, from R&D activities to production sites and across affiliates.Key actions to address quality and safety Mitigating risks related to product safety and quality signalsMitigating safety risks in clinical trialsDescription and year of completionMonitoring and using safety information from patients to take timely and appropriate action to improve product quality and safety. Outcomes are monitored in our risk management system and a risk management plan is prepared in accordance with regulatory requirements.Detailed protocol for each clinical research activity based on scientific methodology and ethical considerations, to be approved by an Independent Ethics Committee, Institutional Review Board or other appropriate bodies, as well as by regulatory authorities prior to study start.Scope of actionAll Novo Nordisk products with marketing authorisation and products in Novo Nordisk sponsored clinical trialsAll Novo Nordisk sponsored clinicaltrialsTarget in placeNo No Overall progress in 2024 and how we track effectiveness ⢠A safety committee with members from all relevant functional areas is established prior to any clinical investigation of a new pharmaceutical product or medical device, providing assessments of safety data throughout the product or deviceâs life cycle.⢠Number of product recalls and failed inspections are reported to track effectiveness. In 2024, we tracked three product recalls and 0 failed inspections.⢠Relevant safety information is continuously assessed during Novo Nordisk-sponsored clinical research activities and appropriate actions taken if risks outweigh potential benefits. In the event of any clinical research-related injury, participants are compensated according to domestic laws.PerformanceTo manage impacts and risks related to product safety and quality signals, Novo Nordisk tracks the number of product recalls. In 2024, we had three product recalls, due to cracked cartridges of insulin products in South Africa, underfilled vials in the Czech Republic and incorrect labelling of products in clinical trials. None of the recalls had serious adverse health consequences. Furthermore, we actively monitor inspections to ensure compliance with health inspection requirements. In 2024, 180 inspections were conducted, and we did not fail any inspections. At year-end, 144 inspections were passed and 36 were in-progress, as final inspection reports had not yet been received, or the final authorityâs acceptance was pending. Follow-up on in-progress inspections will continue in 2025. 3.1.4. Product recalls and failed inspections Unit 2024 2023 2022Product recalls Number 3 2 3Failed inspections Number 0 0 0ACCOUNTING POLICIES Failed inspections Inspections where FDA warning letters or European Medicines Agency non-compliance letters related to Good Medical Practice inspections are received, Good Medical Practice/ISO certificates for strategic sites are lost, pre-approval inspections result in a complete response letter, study conclusions are changed due to Good Clinical Practice/Good Laboratory Practice inspection issues, or marketing or import authorisations are withdrawn due to inspection issues. Strategic sites are defined as the manufacturing sites in Brazil, China, Denmark, France, and the US. Acquired companies' inspections are defined as inspections run by the acquired company. Inspections at acquired companies run by Novo Nordisk are reported as Novo Nordisk inspections. Product recallsNumber of times Novo Nordisk has instituted a recall of a product from the market due to patient safety reasons, including recalls in connection with clinical trials. A recall may affect multiple countries.FALSIFIED MEDICINESPoliciesFalsified medicines are a global problem that pose severe risk to public health and patient safety worldwide. These illegally manufactured products may contain the wrong or incorrectly dosed active pharmaceutical ingredients or harmful substances leading to serious adverse effects. Falsified products are at an all-time high, driven by the surge in demand for weight-loss drugs and injectable products. Novo Nordisk helps investigate suspected cases of pharmaceutical crime and takes a proactive approach to managing negative impacts and risks to patients.The handling of suspected falsified Novo Nordisk products is outlined in our OneCode policy and covered in our quality management system and standard operating procedures, supporting the monitoring, signal detection and reporting to health authorities of alleged occurrences. Further details can be found in our publicly available position on falsified medicines.Novo Nordisk detects falsified medicines through reported product complaints frompatients, healthcare professionals and authorities, as well as through field- and online surveillance by investigative firms. Specialised security services are used to conduct investigations, test purchases and for decommissioning. With the support of local investigation firms, we also perform market searches to help health authorities locate and seize falsified products. We collaborate with authorities in over 20 countries, including Europol and Interpol, to support and facilitate the detection of falsified medicines. Global responsibility for product protection lies with the Head of Global Security who leads our efforts to protect key products and patents.ActionsTo further prevent falsified or mislabelled medicines entering the pharmaceutical distribution system, Novo Nordisk pursues targeted actions as outlined in the table. Unless otherwise indicated, actions are considered recurring. Resources for our product protection programme lie with Global Security, however, the programme is implemented globally at regional and affiliate-level, with more extensive efforts being conducted in high-risk markets. To ensure the continued effectiveness of our actions, Novo Nordisk is a member of the Pharmaceutical Security Institute, which fights falsified medicines worldwide. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Key actions to addressfalsified medicines Product protection end-to-end solutionsAwareness campaigns and trainingDescription and year of completionApplying relevant security features based on risk assessment and regulatory requirements, including reinforcing supply chain integrity through security specifications in distribution and warehouse contracts.Awareness campaigns and onboarding programme to prevent patients from buying medicines outside legitimate channels, including more information for healthcare professionals.Scope of actionGlobal operationsand downstream value chainGlobal operationsand downstream value chainTarget in placeNo No Overall progress in 2024 and how we track effectiveness ⢠In 2024, we continued to review the security of our supply chain including agile testing solutions and rapid testing devices to support swift identification of falsified medicines.⢠We continuously review our approach to the protective features of products, from overt to covert solutions.⢠Rolled out a dedicated, onboarding programme to over 1,600 employees in relevant functions.⢠Launch of awareness programme for law enforcement agencies enabling an increase in seizures of falsified medicines.⢠Launch of other external awareness campaigns for patients via social media and our website. Information-related impacts for patients and clinical trial participantsPoliciesData protection is integrated in our global ethics and compliance framework, as outlined in our OneCode policy and relevant standard operating procedures. Strict data protection applies to all personal data related to patients and clinical trials and is implemented in accordance with all applicable data protection requirements. We outline how we work with data protection in our publicly available data ethics standards and personal data processing principles. Before initiating clinical trials, we ensure that participants are well informed about theirprivacy rights including the legitimate disclosure of data. We disseminate scientific knowledge obtained through clinical trials for the benefit of society. Our commitment to transparency of clinical research activities is outlined in our clinical disclosure and reporting instructions, which are aligned with legal 3requirements and ethical principles and owned by the Head of Regulatory, Quality and Clinical Reporting. Through our clinical reporting and transparency efforts we ensure that results from Novo Nordisk sponsored clinical research activities are disclosed in public registers. To make research more accessible, we aim to publish Plain Language Summaries (PLS) for our phase 3 primary data publications to translate complex scientific information in an easy-to-understand format in accordance with our standard operating procedures.Following successful completion of a clinical trial programme, we work in close collaboration with global health authorities to ensure informative and accurate product labels to guide patientsâ use and outcomes of treatment. Processes for safeguarding labelling quality in the markets in which Novo Nordisk operates are outlined in standard operating procedures, which are the responsibility of Global Regulatory Affairs.We communicate with healthcare professionals about our products to encourage informed use, so they can make the best treatment choices for the benefit of their patientâs health. We have strict guidelines in place to only promote our products for uses that have been approved by the appropriate regulatory authority in a manner that is truthful, accurate, non-misleading, balanced and consistent with the approved product label. Off-label promotion is prohibited as outlined in our OneCode policy.3. Including, but not limited to, World Medical Association Declaration of Helsinki - Ethical Principles for Medical Research Involving Human Subjects.ActionsThe management of information-related impacts and risks is a prerequisite to our operating model. We therefore routinely take action to prevent and mitigate any information-related risks and impacts for patients and clinical trial participants while maintaining strict adherence to all relevant regulations and standards.The management of information-related impacts involves various functions. Our Global Ethics and Compliance Office oversees the global data privacy agenda, together with expert functions throughout the organisation. Ensuring informative and accurate labels is a cross-functional undertaking anchored in our Global Regulatory Affairs Department, working closely with our affiliates, regions and functions engaged in global development programmes. The Clinical Reporting Department ensures transparency of clinical research activities together with colleagues across our global development programme. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Key actions to address information-related impacts Improving transparencyof our Patient Information and Informed Consent forms (PIIC)Communicating and raising awareness of informed use of our productsDescription and year of completionUpdate of PIIC forms to enhance general transparency with respect to i) engaging in Novo Nordisk sponsored clinical trials and ii) how privacy rights of patients are protected. Project expected tobe completed by May 2025.All promotional materials for our respective products undergo robust legal, medical and regulatory review processes. We continuously strengthen our guidance and communication to ensure healthcare professionals are equipped with appropriate information about our products and the underlying clinical data to make the best decisions for patients.Scope of actionIntended for use in global clinical trials. Will be adaptable to local deviationsGlobal operations related to product communication Target in placeNo No Overall progress in 2024 and how we track effectiveness ⢠We continuously assess improvement areas when it comes to privacy rights of patients.⢠Training healthcare professionals on approved indications of our products and key messages around responsible use.⢠Alignment with authorities to support proactive communication to emphasis the indication of our products.⢠Field forces and commercial functions in all markets have been provided with clear guidance on how only to engage in conversations for approved labels of our products.3.2 Own workforceAs a pharmaceutical company, we depend on talented people and innovative ideas. Our workforce spans employees working at our production sites and in laboratories to sales representatives and administrative employees. In light of our current expansion, our workforce has grown substantially to help meet the surge in demand of our medicines. We have in 2024 implemented a sustainable growth strategy, moderating the pace of recruitments in order to ensure a good workplace for all employees.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainEmployee benefits and flexible working conditions⢠Own operationsPotential human rights incidents⢠Own operationsNovo Nordisk upholds good working conditions globally for all employees hired on an employment contract, offering benefits and flexibility to promote employee wellbeing. Novo Nordisk has been voted a top workplace across several countries and regions as part of the Best Places to work programme, highlighting our positive impact when it comes to offering an attractive, global workplace. We do not tolerate any potential human rights violations and will manage any harm according to our procedures. Examples of human rights incidents related to own workforce in Novo Nordisk include potential incidents related to safe and healthy working conditions, right to privacy and data protection as well as employeeâs rights. No specific parts of our operations have been found to be at specific risk of forced or child labour, and most of our employees work in low-risk countries, according to the Global Rights Index.Identified IRO Category Value chainHealthy and safe work environment⢠Own operationsWhen we research, produce and manufacture pharmaceutical products, we aim to operate to the highest health and safety standards, which includes ensuring that employees feel physically and mentally safe regardless of whether they work in a physically demanding or sedentary working environment. We recognise that health and safety incidents can lead to negative impacts for those affected.In 2024, we witnessed serious incidents in connection with the expansion of our production capacity which have resulted in heightened levels of safety measures being implemented across the organisation.Identified IRO Category Value chainEqual opportunities fostering innovation⢠Own operationsTo sustain an innovative work culture, Novo Nordisk has positive impacts on our employees by continuously strengthening our efforts in diversity, equity, and inclusion to ensure that every employee can contribute, feel a sense of belonging and has equitable career opportunities. Furthermore, by offering comprehensive training and development opportunities for all, we support our employees to keep learning and growing.Identified IRO Category Value chainAttracting talent to enable continued innovation⢠Own operationsWe recognise that, as an innovation company, we are exposed to potential risks because our business depends on attracting and retaining talent. We are especially dependent on research and development to sustain continued innovation. The deliberate slowdown in recruitment does not affect our commitment to ensure that we can attract the right skills, experience and qualifications across our global operations.General processes for workforce engagementWe engage with our own workforce both directly and indirectly through multiple processes to inform our decisions. The main way we obtain direct feedback from our employees is through our yearly employee survey Evolve. The survey ensures that we continue to monitor and improve Novo Nordisk as a workplace and all teams work actively with the results every year. Furthermore, we engage with workersâ representatives. In Denmark, employees are represented by local unions and associations, and in European affiliates, workersâ representatives are elected by the employees. In some of our international affiliates, engagement will take place directly with employees. The frequency of engagement varies across our operations; in Denmark, we have scheduled dialogue meetings between management and workersâ representatives at least every quarter. Dialogue with the European Works Council (EWC) secretariat takes place on an ongoing basis, and includes an annual meeting with all EWC representatives. Negotiations on topics such as salary and collective bargaining agreements depend on the agreed time frame. These dialogues support us in assessing the general effectiveness of our employee-related efforts and is implemented by local People & Organisation teams and managers. In Denmark, worker's representatives are also represented at the Board of Directors, further enhancing dialogue and representation.General process for remediation There are multiple ways in which employees can raise workplace-related grievances and concerns, including through the local or global People & Organisation or Legal function, Business Ethics Compliance Office, Group Internal Audit, Novo Nordisk Way facilitations, the annual Evolve survey, onboarding surveys and the Ombudsman function.Individual cases concerning unfair treatment of a particular employee will usually be handled by the Ombudsman function. We will not tolerate discrimination or retaliation against persons who file a report or participate in an investigation in good faith.Employees can always report any concerns anonymously through the publicly available Novo Nordisk Compliance Hotline. The Compliance Hotline is further described in section 4.1 âBusiness conductâ, under 'Compliance Hotline and protection of whistleblowers', on page 91, including our anti-retaliation policy. We place importance on the provision of effective remedy wherever employeesârights have been found to have been negatively impacted.Working conditions and other work-related rightsPoliciesPolicy Labour Code of ConductPurpose Minimum labour standards for our employeesScope All Novo Nordisk employeesMost senior level Executive ManagementaccountableAvailability Externally available: Novo Nordisk Labour Code of ConductApplicability across ⢠Own Workforce, p. 80Sustainability statementSupporting policy ⢠Anti-harassment Frameworkdocumentation1Novo Nordiskâs Labour Code of Conduct details globally adopted minimum labour standards for our employees, to safeguard employees' rights and promote favourable working conditions to remain an attractive workplace. As detailed in our policy, we operate in accordance with all applicable laws and regulations. All employees are required to receive secure employment and adequate income in a standard working week to meet their basic needs, along with discretionary income. This is achieved by maintaining employee salaries and benefits above the living wage of a given country, the statutory minimum wage given by law, prevailing industry benchmarks, or the wage negotiated in collective agreements,whichever is the highest. Periodic assessments and adjustments are made to account for changes in the cost of living and economic conditions.We track permissible working hours to ensure adequate work-life balance. To empower employees, we offer various flexible working solutions. In line with local business requirements, employees can apply for options such as a career break, a compressed working week or reduced working hours according to personal needs. Pay and benefits are adjusted accordingly. Employees are covered by social protection through public programmes or benefits offered by Novo Nordisk.Novo Nordisk respects our employeesâ right to associate freely and to join or refrain from joining labour unions and workersâ councils without fear of discrimination or retaliation. Where the right of freedom of association and collective bargaining is restricted or prohibited under law, we do not hinder employees from developing alternative mechanisms to express their grievancesand protect their rights regarding working conditions. To encourage social dialogue, Novo Nordisk also engages with workers' representatives, for example, through Novo Nordiskâs European Works Council (EWC).We protect equal treatment and opportunities for all employees, including a working environment free from discrimination and harassment. Equality means free from discrimination due to grounds of gender, family status, race and ethnic origin (including colour), national or social origin, religious beliefs, political orientation, sexual orientation and identity, marital status, age, disability or other categories protected by national, state or local laws. Our internal Anti-harassment Framework sets out the global minimum standards for a fair process when handling any cases of harassment at Novo Nordisk and is implemented by local People & Organisation and Ethics & Compliance units. Employees working in North America are safeguarded from harassment and discrimination through a local process and framework.We process employee data as part of conducting our business. Our OneCode policy and Ethics & Compliance programme are the basis for our global privacy and data ethics compliance across the value chain. These set the minimum global standards for how we handle and protect personal data, together with applicable laws and regulations.The Labour Code of Conduct also outlines expected minimum requirements regarding Novo Nordisk employeesâ human rights at work, in line with our Human Rights Commitment. Our policy commits to prohibition, prevention, and mitigation of forced, bonded or debt labour, slavery, servitude, human trafficking and child labour. For information on our human rights policy, we refer to section 3.3 âWorkers in the value chainâ on page 88.ActionsRecurring actions related to working conditions are outlined in the table. Some of our actions supporting our positive working conditions are described in other sections, for example, strengthening of parental leave as described in the section 'Equal treatment and opportunities for all' on page 86. Overall, the effectiveness of our actions is assessed through continuous engagement with our employees and all leaders are expected to tend to the wellbeing of their employees.Resources allocated to managing impacts and risks related to own working conditions are handled by our Global People and Compliance units as well as local People & Organisation teams depending on affiliate size.1. The Labour Code of Conduct is aligned with the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the International Labour Organizationâs Declaration on Fundamental Principles and Rights at Work and the UN Global Compact Ten Principles.Key actions to addressworking conditions in own workforce Mitigating risks related to own workforce or potential human rights breachesDue diligence assessment of Labour Code of ConductDescription and year of completionRisks are assessed and addressed through mitigatingactions on an ongoing basis, in accordance with the enterprise risk management framework. Any remedyis applicable in accordance with, local, legal requirements.In 2024, we have initiated a due diligence assessment ofour Labour Code of Conduct to evaluate the effectiveness of its global implementation since its launch in 2019 to ensure we protect our working condition standards. To be completed in 2025.Scope of actionGlobal operationsGlobal operationsTarget in placeNoNoOverall progress in 2024 and how we track effectiveness ⢠Risk mitigation efforts are carried out continuously, and includes support to relevant affiliates on compliance with for example local legislation. ⢠With respect to human rights efforts, we are in the process of upskilling our workforce to strengthen our due diligence for our own operations.⢠The finalisation of the assessment in 2025 will provideinsights for potential future action plans.Permanent employees Temporary employees Non-guaranteed hours (headcount)(headcount)employees (headcount) Total3.2.2 Characteristics of Novo Nordisk's 2Unit 2024 2023 2022 2024 2023 2022 2024 2023 2022 2024 2023 2022employeesMen Number 34,720 â â 2,696 â â 0 â â 37,416 â âWomen Number 33,920 â â 2,791 â â 0 â â 36,711 â âOther/not reported Number 29 â â 0 â â 0 â â 29 â â2. Total headcount of 77,349 as per note 2.4 'Employee cost' on page 110 in the Consolidated financial statements. The variance of 3,193 employees is due to Catalent employees not being included.33.2.3 Employees and employee turnoverUnit 2024 2023 2022Total number of employees (FTEs) â excluding Catalent FTEs 73,109 63,370 54,393Total number of employees (headcount) â including Catalent Number 77,349 64,319 55,185Total number of employees (headcount) â excluding Catalent Number 74,156 64,319 55,185 ⢠Denmark Number 34,185 28,692 22,916 ⢠EMEA (Europe, the Middle East and Africa), excluding Denmark Number 9,928 8,808 7,954 ⢠North America (US, Canada) Number 9,279 8,315 7,250 ⢠Region China (Mainland China, Hong Kong, Taiwan) Number 6,977 6,485 6,148 ⢠Rest of World (all other countries) Number 13,787 12,019 10,917 Number of leavers Number 3,574 â âEmployee turnover % 5.5 5.5 8.23. Total headcount of 77,349 as per note 2.4 'Employee cost' on page 110 in the Consolidated financial statements. The variance of 3,193 employees is due to Catalent employees not being included.PerformanceTo measure our employee's engagement, we track our yearly employee survey (Evolve) index score. The result of the 2024 employee survey is broadly in line with the one from 2023, with a slight decrease of 1 percentage point of favourable answers. Novo Nordisk continues to score in the top quartile when benchmarked against external organisations regarding having a purpose-driven workplace.3.2.1 Enterprise Evolve score Unit 2024 2023 2022Enterprise Evolve score % 85 86 85In 2024, we continued to expand our business while focusing on being an attractive workplace. We increased our workforce by 9,837 employees since 2023, ending the year with 74,156 employees. The most significant increase was at our production sites, particularly within manufacturing and quality, as well as professionals within Digital & IT. Aligned with our sustainable growth objectives, we continue to safeguard the wellbeing of our employees. Our focus resulted in an employee turnover of 5.5%, consistent with 2023.Currently, Novo Nordisk's HR systems allow employees to select the gender with which they most identify. We are committed to increasing awareness of this self-identification option for future disclosures to disclose on other/not reported.To support our policy of employees having the right to form or join associations and to bargain collectively, we began reporting on the number and percentage of collective bargaining coverage for Denmark in 2024. There are five collective bargaining agreements currently in effect, covering 32% of the workforce in Denmark. All employees covered by collective bargaining agreements in Denmark are also covered by workers' representatives, resulting in a 32% representation. With respect to adequate wages, we provide employees with pay that is above the living wage in the given country.3.2.4 Collective bargaining agreements and workers' representatives coverage Unit 2024 2023 2022Number of collective bargaining agreements â Denmark Number 5 â âPercentage of employees covered by collective bargaining agreements and workers' representatives â Denmark % 32 â âIn 2024, Novo Nordisk had 167 substantiated people-related cases, which is based on people who have filed a complaint or concern of different levels of severity and which have been confirmed. Hereof, 139 cases related to harassment, including discrimination. None were deemed as severe cases of human rights incidents. Various activities took place during the year to ensure awareness of speak-up channels and completeness of data. In 2024, the architecture of our grievance mechanisms has been improved and the internal governance has been strengthened, to support registration of incidents reported and investigated locally. We will continue to promote our speak-up culture and anti-harassment framework as part of our company-wide campaigns. We acknowledge that there may be cases which are not being reported to our Compliance Hotline.3.2.5 Incidents, complaints and severe human rights impacts Unit 2024 2023 2022â âSubstantiated people-related cases Number 167⢠Hereof substantiated cases of harassment, including discrimination Number 139 â â⢠Hereof substantiated cases of severe human rights incidents Number 0 â â⢠Hereof breaches of the UNGPs Number 0 â â⢠Hereof number of complaints filed against Novo Nordisk to National Contact Points for OECD Multinational Enterprises Number 0 â âAmount of material fines, penalties and compensation related to the above mentioned incidents mDKK 0 â âACCOUNTING POLICIES Enterprise Evolve score Measures the average percentage of favourable answers to the 18 engagement items shared in Novo Nordiskâs annual employee survey. Favourable answers are defined as âAgreeâ and âStrongly agreeâ to positively framed questions. The survey is administered by an external vendor.Employees (headcount)Measured as the headcount of all employees at year-end, excluding externals, employees on unpaid leave, interns, Bachelorâs and Masterâs thesis employees and substitutes. Employee data is based on registrations in Novo Nordiskâs HR systems. Employees are attributed to geographical regions according to their primary workplace.Number of leaversThe number of employees, excluding temporary employees, who left the Novo Nordisk Group during the year.Employee turnoverMeasured as the number of leavers during the financial year, divided by the average number of employees, excluding temporary employees. Employees working for Group companies that have been sold are not counted as having left the Group.Collective bargaining agreements and worker's representativesComprises the absolute number of the different types of collective bargaining agreements based on specific employee sub-groups (administrative, technicians, operators, skilled workers, etc.) in Denmark. Percentage of employees covered by collective bargaining agreements and workers' representatives are calculated as headcount covered in Denmark at year-end divided by total headcount in Denmark at year-end.Substantiated people-related casesCases that, through a formal process, have been reported to or filed with the Compliance Hotline and have been substantiated or partially substantiated based on an investigation during the year. Cases are within the overarching categories of the global anti-harassment framework, the Novo Nordisk Way and Ombudsman, aswell as other potential human rights breaches for internal employees, consultants and other externally hired individual workers.Substantiated cases of harassment, including discriminationCases that have been closed as substantiated or partially substantiated based on an investigation under the Novo Nordisk Way and the global anti-harassmentframework for our own workforce.Severe human rights incidentsAny substantiated case of severe adverse human rights impacts (child labour or forced labour) reported via Novo Nordiskâs Compliance Hotline for our own workforce, that has been closed during the year based on an investigation. Breaches of the UNGPsIncidents presenting a breach to the United Nations Guiding Principles on Business and Human Rights.Complaints filed with OECD Multinational Enterprise Contact Points Cases filed against a Novo Nordisk legal entity (parent or affiliate) under the OECDâs database of specific instances. Amount of material fines, penalties and compensation related to the above-mentioned incidents Damages resulting from violations of social or human rights laws, including discrimination and severe human rights incidents, where a Novo Nordisk legal entity (parent or affiliate) has been found in violation by a court of law and been condemned to pay material fines, penalties or compensation. Health and safetyPoliciesPolicy Health and SafetyPurpose Ensure safety, mental and physical wellbeingScope Applies across all operations, including contractors Most senior level Executive Managementaccountable Availability Externally available: Health and SafetyApplicability across ⢠Own workforce, page 80Sustainability statementSupporting policy ⢠Local health and safety instructionsdocumentationNovo Nordisk's Health and Safety policy focuses on a holistic approach and encompasses safety, physical wellbeing, mental wellbeing and health promotion, with the overall goal of prevention and continuous health improvements. The objectives of the policy are to ensure high standards in our operations, promote a healthy lifestyle, make employees and leaders accountable for workplace safety, ensure that the working environment is not compromised for economic or productivity reasons, and fulfil all necessary legal requirements.Our policy is implemented through our health and safety management system, which applies to Novo Nordisk employees globally. The system includes specific health and safety requirements, for instance regarding risk assessments, emergency procedures and preparedness. The procedures are supported by dedicated training of all managers and health and safety employees as well as basic training of employees globally. All our production facilities are certified by international standards for health and safety (ISO 45001) and are regularly audited internally and externally.ActionsOur health and safety actions are implemented in a partnering approach with all business areas across the Group. Internal functions responsible for the actions include a global Health and Safety unit, which sets the direction and collaborates across business areas dedicated specifically to health and safety. Furthermore, the health and safety management system includes requirements for the involvement of employees across the group.PerformanceIn 2024, Novo Nordisk had 173 accidents, primarily related to production expansion. Several actions were immediately taken across Novo Nordisk, including to ensure that work permits are in place for all non-routine high-hazardwork such as hot work and working at height. Moreover, emergency procedures have been reviewed and emergency response teams have been established where not already in place. From 2025, Novo Nordisk will introduce a new, global safety target to sustain and enhance focus on driving prevention of potential andserious accidents.To measure progress against our local and global health initiatives, we set targets applicable across our global operations to reduce and prevent accidents from occurring. Our safety target has the aim of 10% annual improvement in rate of recordable work-related accidents (also commonly referred to as Lost Time Accident Frequency (LTAF) or Lost Time Injury Frequency (LTIF)).Key actions to addresshealth and safety Local health and safety action plansSpecific actions related to health and safety incidentsDescription and year of completionA bottom-up management review is conducted on an annual basis to assess the effectiveness of the health and safety management system. Each business area has committed to a local health and safety plan addressing all strategic focus areas and relevant risks associated.Any remedy is provided based on local, legal requirements and global support options are made available for affected employees.In response to expansion-related health and safety risks, further measures have been implemented in 2024 to prevent fire-related accidents in the future, including mapping of high-risk activities, establishing work permit offices, and review of emergency response plans.Scope of actionGlobal operationsGlobal operations,with a focus on capacity expansion projectsTarget in placeYesNo Overall progress in 2024 and how we track effectiveness⢠Safety: Performance against health and safety metrics include 173 recordable work-related accidents. Several actions were taken to ensure that safety is systematically addressed. ⢠Mental wellbeing: 13.8% of employees reported symptoms of stress. Areas with a high level of stress symptoms have been offered support from an organisational psychologist, focusing on organisational aspects, psycho-social factors and leadership.⢠Physical wellbeing: 6.8% reported symptoms of work-related physical pain. Targeted efforts in areas with a high level of work-related pain has been piloted supporting local business areas to address root causes systematically. Further, interventions in Denmark and competency building on work-related pain at global production sites have been conducted.⢠NovoHealth: The employee health promotion programme focuses on physical activity, healthy eating, individual mental wellbeing, nicotine cessation, weight management and health checks. ⢠New safety KPI was developed, applicable from 2025, expanding the scope of reported accidents and investigations to further prevent incidents across 10 high-risk hazards, including activities related to working at heights and hot work.Year-on-year3.2.6 Health and safety (own employees) Unit 2024 2023 2022reduction targetWorkforce covered by health and safety management system (headcount) % 100 â âRecordable work-related accidents Number 173 153 1284Accidents per million Rate of recordable work-related accidents1.2 1.3 1.3 10%hours workedFatalities as result of work-related injuries Number 0 1 2Employees reporting symptoms of stress % 13.8 13.8 13.8 10%Employees reporting symptoms of work-related physical pain % 6.8 7.1 7.8 5%4. Rate of recordable work-related accidents was previously reported as Frequency of occupational accidents. Figures for 2022 and 2023 have been restated from 1.5 accidents per million hours worked in both years.The calculation method for the rate of recordable work-related accidents was changed as of January 2024 to follow the international standard definition, harmonising the FTE equivalent working hours to 2,000 hours a year compared to the previous 1,600 hours, and using an average FTE number instead of year-end figures. The rate of recordable work-related accidents decreased by 8% in 2024, which does not meet the 10% annual improvement target. In 2024, it was reduced to 1.2 accidents per million hours worked compared to 1.3% in 2023. The decrease is primarily caused by an increased safety focus from top management, based on awareness of the elevated risk level connected to production expansion. This focus has been communicated down through line of business and has been supported by clearer safety requirements and safety behaviour initiatives. In 2024, Novo Nordisk had 173 accidents with reported absence compared to 153 in 2023, which is in line with the increase in the number of employees. Furthermore, Novo Nordisk had zero work-related fatalities in 2024 compared to 1 in 2023.To improve mental and physical well-being, we have set targets to reduce the number of employees reporting symptoms of stress by 10% year-on-year and to reduce employees reporting symptoms of work-related physical pain by 5% year-on-year. In 2024, 13.8% of employees responded that they had experiencedsymptoms of stress, which is in line with the 2023 result, hence the target of 10%annual improvement has not been met. The reasons are many and vary across the organisation. The overarching cause is the growth of the company, leading to both onboarding-related burdens and organisational changes which are known risk factors to mental wellbeing. In Production and Operations, the demand for supply adds significantly to the strain. In many other areas, the increased complexity arising from the expansion of our portfolio is a contributing factor to stress. In 2024, specific training and follow-up guidance with focus on mental well-being was offered for relevant teams. Furthermore, a global mental well-being delivery model targeting areas with a high stress level has been implemented to both reduce and prevent stress. We will continue to implement new initiatives throughout 2025 to further improve performance.Reported symptoms of work-related physical pain decreased by 4% from 7.1% in 2023 to 6.8% in 2024. Hence, the target of 5% year-on-year improvement has not been met. The delivery model for physical wellbeing was only initiated in 2024 and the full results of this remain to be seen. Across all targets, the health and safety management system ensures that we involve our own workforce, including health and safety representatives, in target setting, performance tracking and when identifying lessons learned. Insights from the annual employee engagement survey, Evolve, also informs our target setting. Monitoring occurs on an ongoing basis and is reported annually.ACCOUNTING POLICIESWorkforce covered by health and safety management system (headcount) The percentage of employees in Novo Nordisk's own workforce who are coveredby our health and safety management system based on legal requirements and/or recognised standards or guidelines is defined as the number of employees covered by health and safety management systems (headcount) divided by all employees (headcount). Recordable work-related accidentsTotal number of work-related injuries causing at least one day of absence in addition to the day of the accident.Fatalities as a result of work-related injuriesWork-related accidents resulting in the death of an employee. All employees (headcount), permanent, temporary, and non-guaranteed hours, have been included in this metric. Rate of recordable work-related accidentsRate of recordable work-related accidents for our own workforce, measured in accidents per million hours worked, also referred to as the lost-time accident frequency (LTAF). Contractors, visitors, employees on unpaid leave, interns, and Bachelor's and Master's thesis students are not included. The number of hours worked is based on 2,000 working hours annually per full-time equivalent and the monthly records of number of employees converted into full-time equivalents. Percentages of employees reporting symptoms of stress/work-related physical pain Reported via the annual employee survey Evolve. In the survey, stress is defined as a situation where the employee feels tense, restless, nervous or troubled, or unable to sleep at night due to thoughts about their problems. Regarding symptoms of physical pain, the survey asks if an employee's work generally causes them physical pain. The two relative targets of improving mental and physical wellbeing are measured as the percentage of employees responding 'Quite much' or 'Very much' for mental wellbeing or 'Unfavourable' to the statement related to physical pain.Equal treatment and opportunities for allPoliciesPolicy Diversity and InclusionPurpose Guides our actions to promote equal opportunitiesScope All Novo Nordisk employeesMost senior level Executive Managementaccountable Availability Externally available: Diversity and inclusion policy Applicability across ⢠Own workforce, page 80Sustainability statementBy offering a diverse and inclusive workplace with opportunities to continuously learn and grow, Novo Nordisk can help foster the best conditions for employees and sustain continued innovation. Our diversity and inclusion (D&I) policy defines diversity as the mix of employees, perspectives, and backgrounds we have in our business, and inclusion as creating a culture where all employees feel valued and have a sense of belonging. We recognise that diversity is any dimension that differentiates our people and enables diverse thinking, for example gender, ethnicity, race, nationality, disability and sexual orientation. To foster equal treatment, our D&I policy focuses on mitigating bias, creating an inclusive workplace, and having leaders serve as role models. Novo Nordisk actively seeks input from employees, senior leadership and peers to ensure that efforts reflect the needs and aspirations of our workforce and aligns with societal values and expectations. Equal opportunities in Novo Nordisk also means creating a strong learning culture, embedded in a set of core beliefs that focus on how we ensure a shared and deliberate approach to personal and professional growth. While we do not have a specific training policy, we are guided by internal standard operating procedures for compliance driven and job specific training. The procedures serve as process guides for identifying, providing, evaluating and documenting relevant training for each employee to comply with the healthcare-regulated requirements related to their job. Compliance-driven training varies depending on the need of the business unit.To maximise the potential of ongoing dialogue between employees and managers, we focus on individual development plans and dedicated talks to discuss growth, where employees engage with their managers regarding, for example, training opportunities and career aspirations.ActionsTo foster equal opportunities, the outlined action plans support the implementation of our policy commitments. Unless otherwise indicated, actionsare considered recurring. In consideration of the local context and societal norms we ask all areas to determine local aspirations and action plans applicable to their geography.Internal functions involved in execution of our actions include our Global D&I team, which sets the strategic direction and targets for Novo Nordisk. D&I professionals and champions align aspirations and action plans with the global direction.Our balanced gender representation targets are aspirational goals and Novo Nordisk is dedicated to providing equal employment opportunities for all, regardless of gender. We have a merit-based recruitment strategy and endeavour to hire the most qualified person for the job based on their skills, experience and qualifications across our global operations.Key actions to address equal treatment and opportunities Mitigate bias through equal pay reviewsInclusive workplace through balanced gender representation Inclusive workplace through flexible workingpoliciesRoll-out of training offeringsDescription and year of completionEnsure that individuals with similar roles and responsibilities are compensated equitably, regardless of background, gender, or ethnicity. Equal pay reviews are conducted on a quarterly basis with corrective actions for confirmed equal pay risk cases.Striving for balanced gender representation across managerial levels, through for example ensuring a diverse slate of candidates, diverse recruitment panel and pipeline of diverse talents. Improved minimum global standards for paid maternity leave and paid parental leave for non-birthing parents as well as paid leave for employees to handle serious health conditions of their dependents. Changes are applicable from January 2025.Employee training based on target group, qualifications and job requirements to inspire positive leadership habits and empower potential at all levels. Training offerings cover both compliance-related training but also development options throughglobal talent and development programmes, virtual and face-to-face skill courses, and online learning content. Scope of actionGlobal operations, excluding US and Canada following own processesGlobal operationsGlobal operationsGlobal operationsTarget in placeNo YesNoNoOverall progress in 2024 and how we track effectiveness ⢠In 2024, out of the around 62 thousand positions covered in the pay review, we identified 0.13% â compared to 0.6% in 2023 â with an equal pay gap and we are taking corrective actions.⢠The equal pay review goes beyond gender and considers various parameters to identify gaps using employeeâs job level, job family, tenure, country.⢠Men account for 54% in leadership positions and 58% in senior leadership positions.⢠Women account for 46% in leadership positions and 42% in senior leadership positions.⢠Introduction of a global minimum standard of parental leave within the first year of becoming a parent extended from 8 to 14 weeks for all non-birthing parents globally. ⢠Introduction of a global minimum standard of 2 weeks of paid leave annually for employees who need time to handle a serious health condition of dependents.⢠In 2024, new compliance-related training was established regarding product quality, safety and efficacy, impacting around 6,000 managers.⢠Approximately 4,000 out of nearly 9,000 leaders engaged in our development programmes, and about 2,000 employees completed global strategic capability development programmes.⢠More than 40,000 times employees and leaders have completed a learning item online to help develop specific skills.⢠Progress of training programmes are monitored through voluntary surveys following course completion.PerformanceIn 2021, we set a global target to achieve balanced gender representation across all managerial levels, and a minimum of 45% women and 45% men in senior leadership roles by the end of 2025. The target is applicable across our operations. The target was set based on various benchmarks, including pharmaceutical peers, other global Danish companies, industry-leaders and research, and was developed in collaboration with leaders and People & Organisation representatives and approved by the Board of Directors. We are transparent regarding tracking performance against this target. In 2024, 46% of all leadership positions were filled by women, the same as in 2023. Within senior leadership, 42% of positions were filled by women at the end of 2024, in line with 41% at the end of 2023. As of 31 December 2024, the Board of Directors had equal gender representation, consisting of six female and six male members. Moreover, when excluding employee representatives, the shareholder-elected Board members comprise of three female and five male members. According to the Danish Companies Act, this is regarded as having equal gender representation,and Novo Nordisk is therefore not legally required to set a gender target. Since diversity remains important for the Board, it has maintained a voluntary 2026 target of having at least three shareholder-elected Board members who are women and three who are men. Diversity in the broadest sense remains a focus area for the Board of Directors, including Board member searches. Novo Nordisk is reporting on the gender pay gap for the first time. In 2024, the aggregated gender pay gap is 3% in favour of women. We continue to work actively with equal pay, for example through our equal pay reviews as described in the action section, according to which 0.13% of positions where identified to have an equal pay gap, when taking into account various parameters beyond gender. To ensure that we provide equal treatment and opportunities for all, we track the age distribution among our employees, which largely remains unchanged year over year.Across all of our D&I efforts, we monitor our global Inclusion Index, which is part of our annual employee engagement survey, Evolve. It indicates how our employees rate the state of inclusion at Novo Nordisk, and it resulted in 82% of our employees rating the inclusion statements favourably in 2024.Men Women3.2.7 Diversity metrics â Management levels Unit 2024 2023 2022 2024 2023 2022Number of employees (headcount) at senior leadership â CEO, EVP, SVP Number 38 â â 22 â âPercentage of employees (headcount) at senior leadership â CEO, EVP, SVP % 63 64 71 37 36 29Number of employees (headcount) at senior leadership â CVP, VP Number 466 â â 339 â âPercentage of employees (headcount) at senior leadership â CVP, VP % 58 59 60 42 41 40Number of employees (headcount) at other leadership levels â Director, manager, team leader Number 4,726 â â 4,171 â âPercentage of employees (headcount) at other leadership levels â Director, manager, team leader % 53 54 55 47 46 45Gender in leadership positions (overall) % 54 54 56 46 46 44Gender in senior leadership positions (CEO, EVP, SVP, CVP and VP) % 58 59 61 42 41 39 Target: minimum 45% men and 45% womenGender on the Board of Directors % 50 50 54 50 50 46Gender on the Board of Directors without employee representatives % 62 62 67 38 38 333.2.8 Remuneration metrics Unit 2024 2023 20225Gender pay gap % (3)â âAnnual total remuneration ratio Ratio 63 â â5. Negative gender pay gap shows a pay gap in favour of women. 3.2.9 Employees by age group Unit 2024 2023 2022Under 30 years old Headcount 11,538 â â% 16 17 15Between 30 and 50 years old Headcount 48,429 â â% 65 64 65Over 50 years old Headcount 14,189 â â% 19 19 20ACCOUNTING POLICIESGender in leadership and senior leadership positionsReported as the percentage split by gender in leadership and senior leadership positions. Senior leadership positions are defined as employees in the global job levels chief executive officer (CEO), executive vice president (EVP), senior vice president (SVP), corporate vice president (CVP) and vice president (VP). These are the top management positions in the Novo Nordisk Group. Other leadership levels are defined as employees in the global job levels of director, manager and team leader. Leadership positions overall are defined as directors, managers, team leaders and senior leadership positions. Diversity on the Board of Directors is reported as the percentage split by gender among all members, including employee elected members.Gender pay gap Calculated as the difference between the average annualised salary for men and women divided by the average annualised salary for men, and expressed as the percentage of the average annualised salary for men. All employees at all job levels and in all countries have been included in this metric. Calculations were performed for the full consolidation, regardless of job level and country. Annual total remuneration ratio Calculated as the ratio between the annual retribution of the highest paid individual and the annual total remuneration for all employees.3.3 Workers in the value chainAs a global company, Novo Nordisk depends on a large value chain of more than 60,000 suppliers providing goods or services to enable our business. We therefore impact workers in our global supply chain both directly and indirectly, for example when sourcing materials used to manufacture our medical products, when hiring external contractors for our expansion projects, or through logistic partners when distributing our products. While our suppliers are concentrated primarily in Denmark, the US, and China, we aim to ensure all of our partners across our global value chain meet and uphold the expected minimum requirements for human rights, social, health and safety and environment.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainProtecting working conditions and human rights⢠Upstream⢠DownstreamGiven the size of our value chain, we acknowledge negative impacts can occur where we fail to identify or follow-up on cases where suppliers do not meet our standards. Based on supplier audit findings, negative impacts relate primarily to individual incidents, such as worker protection issues or working hours not meeting our standards. We acknowledge that human rights violations can occur across our value chain, and we will continuously review our due diligence and risk assessments to identify potential and actual human rights violations that we may cause or contribute to. Currently, we have not identified any geographies or commodities in our value chain that are exposed to significant risks of human rights violations. We also have not identified any specific group of value chain workers that is particularly vulnerable to negative impacts.Process for engagement and remediationWe engage directly and indirectly with supplier representatives through our ongoing engagements across sourcing units as well as through supplier audits. Our various procurement functions are responsible for ensuring engagement is conducted in accordance with Novo Nordiskâs Responsible Sourcing Programme. Our policy specifies that suppliers must implement procedures that allow all employees to raise and address workplace grievances anonymously without fear of reprisal or retaliation. Furthermore, all value chain workers can raise any concerns, including grievances related to human rights through our Compliance Hotline. The Compliance Hotline is further described in the section âBusiness conductâ on page 91. We do not have other formalised processes for engaging directly with value chain workers.Working conditions and equal treatment and opportunities for allPoliciesPolicy Responsible Sourcing StandardsPurpose Expected minimum requirements for our partnersAll global suppliers providing goods or services to Scope Novo NordiskMost senior level Senior Vice President of Global Solutionsaccountable Externally available:Availability Responsible Sourcing StandardsApplicability across ⢠Workers in the value chain, page 88Sustainability statement⢠Business conduct, page 90The purpose of Novo Nordiskâs Responsible Sourcing Standards is to safeguard human rights in the workplace, protect labour and social rights, establish safe, secure and healthy working conditions, and minimise negative environmental impacts. The policy is built on internationally recognised legislations and standards such as the Corporate Sustainability Due Diligence Directive, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the International Labour Organisation.The minimum requirements outlined in our policy cover all global suppliers and include, but are not limited to, manufacturers, contractors, agencies, distributors, transportation carriers and technology partners. In 2024, we have updated our Responsible Sourcing Standards by strengthening existing policy principles as well as covering additional social and human rights requirements aligned with the Corporate Sustainability Due Diligence Directive (CSDDD). Going forward, the policy is a requirement in all new contracts and will be rolled out in a phased approach across our global value chain.To promote good working conditions for value chain workers, our policy includes principles for appropriate working hours, adequate wages, secure employment, and ensuring that workers are paid on time and in full, according to applicable wage laws, including minimum wages, over-time and mandated benefits. Labour rights should be promoted, as set forth in applicable laws, enabling workers to associate freely, join or not join labour unions, seek representation, and join workersâ councils in support of social dialogue. Suppliers are also required to protect workers from exposure to workplace hazards through regular review of health and safety policies, regulations and processes, provide necessary worker protection and safety equipment, implement emergency plans and train workers accordingly. With Novo Nordisk undertaking several global capacity expansion projects we have implemented global minimum construction safety standards. Safe working conditions also refer to physical and mental health including a workplace free from harassment.To monitor the implementation of the Responsible Sourcing Standards, we conduct selected audits of our strategic suppliers each year, during which corrective action plans can be devised in event of breach of the policy. We follow up to ensure resolution of issues. If a supplier fails to comply with the corrective action plan, Novo Nordisk reserves the right to terminate the contract with the supplier, depending on the extent of the breach.Other work-related rightsPoliciesPolicy Human Rights CommitmentPurpose Guiding all behaviour with respect to human rightsScope All individuals who can be impacted by Novo Nordisk's activities and business relationshipsMost senior level Chief compliance officeraccountable Availability Externally available: Novo Nordisk Human Rights CommitmentApplicability across ⢠Patient protection and quality of life, page 71Sustainability statement⢠Own workforce, page 80⢠Workers in the value chain, page 88⢠Business conduct, page 90Our Human Rights Commitment defines adequate human rights protection and refers to all internationally recognised human rights instruments, including the International Bill of Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, and the Convention on the Rights of the Child.To live up to the commitment, we pay particular attention to the rights of, as well as the challenges faced by vulnerable groups. In addition, we strictly prohibit the use of any form of forced labour or human trafficking, and expect our suppliers to take the necessary steps to prevent this from happening in their own business or supply chain. Suppliers are also expected to ensure the protection, security, and lawful use of personal data of workers in the value chain, and to ensure, at a minimum, compliance with all applicable privacy and data protection laws. The process for monitoring the implementation of the Human Rights Commitment within the value chain and our own operations include identifying and assessing both materialised and emerging human rights risks within business relationships. Assessment is in accordance with our enterprise risk management framework. For suppliers in scope for a responsible sourcing audit, audits may be extended if indicators from a pre-audit survey show heightened human rights risks.ActionsThe Responsible Sourcing Programme is being implemented across our global procurement teams responsible for the various sourcing categories. This is to ensure the identification and mitigation of negative impacts and risks by engaging with suppliers, conducting supplier audits, developing corrective action plans and monitoring progress. Global actions have been initiated as outlined in the table. Individual incidents found in 2024 as part of our responsible sourcing audits is further described in the section 4.1 'Business conduct' with regards to management of relationships with suppliers on page 92, for which remediation of findings is still ongoing. We will continuously assess relevant sustainability performance indicators to include in future disclosures.Key actions to address workers in the value chain Strengthened the Responsible Sourcing StandardDescription and year of completionUpdate of policy from October 2024, making it mandatory for all new contracts going forward. To initiate the process we focus on larger contractsand strategic suppliers. Policy requirements are aligned with external legal firm and CSDDD.Scope of actionGlobal suppliersTarget in placeNoOverall progress in 2024 and how we track effectiveness⢠Since October, we have started to work in a phased approach to ensure that all our suppliers globally adopt Responsible Sourcing Standards in new or renegotiated contracts. We aim to complete our efforts by 2027. Effectiveness and progress will be assessed continuously.4. Governance4.1 Business conductNovo Nordisk takes a proactive approach to ensuring uniform and ethical business conduct across markets to increase trust in our company andmaintain and improve relationships with our key stakeholders. Furthermore, we endeavour to further strengthen the trust of our investors, business partners, employees, and the public through open and transparent corporate communication.Material impacts, risks and opportunities (IROs)Identified IRO Category Value chainEthical working culture through Novo Nordisk Way⢠Own operationsAt the core of our efforts to uphold high standards of business ethics is the Novo Nordisk Way. This is a set of corporate culture commitments which help guide our employeesâ ethical behaviour and interaction with our value chain partners. We conduct facilitations to ensure that all employees live up to our cultural commitments. This is to safeguard our employees, and reinforce that we live up to our cultural commitments also outside of Novo Nordisk. We continue to assess if we live by our commitments, including through our reputational score.Identified IRO Category Value chainInteracting with all stakeholders in accordance with ⢠Upstreamour business ethics standards⢠Own operations⢠DownstreamWhile we follow all relevant local and international laws, principles, standards and codes when it comes to business conduct, negative impacts can occur if we fail to uphold our business ethics standards in our interactions, especially in geographies that rank low in Transparency Internationalâs Corruption Perceptions Index (CPI). The identification of material IROs in relation to Negative impactPositive impact Opportunity Riskbusiness conduct matters was undertaken at a global level, but with consideration of countries ranked low in the CPI. We ensure that interactions with our stakeholders are compliant with our business ethics standards, including with healthcare professionals, public officials and third party representatives. Despite having strong compliance procedures in place, we recognise that any violations can have negative impacts on society or stakeholders in our value chain.Identified IRO Category Value chainPromoting public health⢠DownstreamIn our interactions with public healthcare systems and their stakeholders, we promote public policy and societal positions through our public affairs efforts onpublic health and serious chronic diseases, thus helping to protect the wellbeingof patients, the healthcare system and wider society.Identified IRO Category Value chainUpholding high bioethical standards⢠Own operationsNovo Nordisk faces several complex bioethical issues during the discovery, development and production of pharmaceutical products. We set high bioethicalstandards to ensure good business conduct during the innovation phase. These are essential for protecting and preventing harm to society while simultaneouslypromoting trust when advancing public health and scientific knowledge. We do not compromise the protection of ethical considerations in the pursuit of new scientific breakthroughs.Identified IRO Category Value chainReliance on animals in research⢠Upstream⢠Own operationsThe use of living animals is still crucial in research for new medicines. Novo Nordisk's use of animals for research has negative impacts for the animals. While the strictest procedures are in place to ensure high ethical and welfare standards, it is still expected that the quality of life of animals is affected.Corporate culturePoliciesThe Novo Nordisk Way, through its 10 Essentials (see page 15), describes the values and behaviours that guide everything we do, rooted in the principles and vision of our founders. Our OneCode policy supports us in living up to the Novo Nordisk Way, guiding everyone employed by, or working on behalf of, Novo Nordisk, on how to act as a company and as individuals, including what constitutes a healthy workspace and our speak-up culture. For more on our OneCode policy, see section 3.1 'Patient protection and quality of life' on page 72.PerformanceA team of facilitators evaluates the adherence to the Novo Nordisk Way of selected units on rotation every year. In 2024, a total of 51 units were facilitated, compared to 42 in 2023. We will continue to increase the number of facilitations to match Novo Nordisk's growth. The units facilitated in 2024 represent 29,021 employees across Novo Nordisk's operations, of which approximately 3,000 employees were interviewed, as well as 600 employees collaborating closely with the units in scope of facilitation. All units were assessed to be working in accordance with the Novo Nordisk Way and no immediate actions were required. Across all units facilitated, Novo Nordiskâs rapid growth, organisational changes, and efforts to increase product supply are the main factors driving improvement opportunities.4.1.1 Facilitations of the Novo Nordisk Way Unit 2024 2023 2022Facilitations of the Novo Nordisk Way Number 51 42 36ACCOUNTING POLICIESFacilitations of the Novo Nordisk WayA facilitation is an internal process for assessing adherence to the Novo Nordisk Way. The number of facilitations is measured as the number of facilitations completed. The assessments are based on a review of documentation and feedback from stakeholders, followed by an on-site visit during which randomly selected employees and management are interviewed. Identified gaps and improvement opportunities related to the Novo Nordisk Way are presented to, and discussed with, Executive Management. The facilitators and Executive Management agree on an action plan to address any gaps and improvement opportunities. Anti-corruption and anti-briberyPoliciesRooted in the Novo Nordisk Way, our OneCode policy also reflects our company-wide commitment to doing business ethically and with integrity, to protect Novo Nordisk and our business partners from engaging in any form of corruption and bribery.To ensure our employees understand the implications of the OneCode policy, we conduct annual ethics and compliance training and tests in the form of mandatory e-learning for all employees and monitor the completion rate, while following up with employees to ensure completion of the training. Additionally, Group Internal Audit performs business ethics reviews to ensure compliance with our business ethics standards.In Novo Nordisk we have not yet defined functions-at-risk, however, ethics and compliance training is mandatory for all employees globally, including for employee-elected members of the Board of Directors. As they are not Novo Nordisk employees, the shareholder-elected members of the Board of Directors receive annual training in our OneCode policy. As a part of our OneCode policy, we focus on complying with all local and international anti-corruption regulations that may apply to our business, such as the US Foreign Corrupt Practices Act, the UK Bribery Act and the UN Guiding Principles on Business and Human Rights.PerformanceWe continue to have almost full coverage of our global mandatory ethics and compliance training. The remaining 1% is mainly due to employees being on leave. Additional targeted measures, such as the annual Ethics Days, help raise awareness, and we will continue to assess such initiatives in the future to further strengthen performance.4.1.2 Prevention and detection of corruption and bribery Unit 2024 2023 2022Employees trained in ethics and compliance % 99 99 99As in 2023, we continue to report zero convictions for breaches of anti-corruption and anti-bribery laws. The amount of fines for violation of anti-corruption and anti-bribery laws, an additional metric introduced in 2024, also amounted to zero.4.1.3 Incidents of corruption or bribery Unit 2024 2023 2022Convictions for violation of anti-corruption and anti-bribery laws Number 0 0 0ACCOUNTING POLICIESEmployees trained in ethics and complianceThe mandatory ethics and compliance training for employees working at Novo Nordisk comprises globally applicable e-learning. The percentage of employees trained is calculated as the number of employees that have completed the training divided by the total number of employees at year-end.Number of convictions for violation of anti-corruption and anti-bribery lawsAnti-corruption and anti-bribery instances where any reported undertaking has been found in violation by a court of law. Compliance Hotline and protection of whistleblowersPoliciesPolicy Anti-retaliation policyPurpose Protection of any persons who report or participate in an investigation in good faithScope Any user of the Compliance Hotline, whether employees or external stakeholdersMost senior level Chief Compliance Officeraccountable Availability Externally available: Compliance HotlineApplicability across ⢠Patient protection and quality of life, page 71Sustainability statement⢠Own workforce, page 80⢠Workers in the value chain, page 88Our employees are encouraged to speak up about ethical or compliance concerns and thereby contribute to an ethical culture at Novo Nordisk.All employees and external stakeholders can report concerns of misconduct in a secure and confidential manner, with the option of anonymity, through the Compliance Hotline or in person. All employees are informed about our hotline as part of their annual ethics and compliance training. We continually assess the effectiveness of the Compliance Hotline, including an assessment every two years,conducted by a third party to ensure trust of the channel and processes.The concerns reported can be related to business ethics misconduct, accounting issues, fraud, bribery and corruption, quality misconduct, breaches of antitrust laws, environmental legislation and data privacy, departures from the Novo Nordisk Way, and misconduct such as espionage, sabotage, information security violations or other serious offences.For each report in scope of the investigational process, an internal lead investigator will be appointed working objectively and independently, under confidentiality obligations, and trained to safeguard investigative information. We reply to all complaints within a few days and confirm the closure of the investigation when finalised. Results and significant ongoing investigations are reported on a quarterly basis to the Audit Committee and Executive Management, including updates on severe cases, general trends, and corrective actions, such as sanctions. Novo Nordisk has established a global Disciplinary Sanction Guideline to ensure the best possible alignment of disciplinary sanctions across the organisation. The guideline is based on two severity factors: intent and frequency. The processes and sanctions in this guideline do not overwrite local employment laws and any relevant collective agreements, which shall be followed at all times.We have zero tolerance for discrimination or retaliation against whistleblowers. Anyone who retaliates against an employee reporting misconduct will be subject to disciplinary action, up to and including termination in accordance with our policy. Novo Nordiskâs measures to protect whistleblowers are in line with the EU Whistleblowing Directive (EU Directive 2019/1937), with which we must comply, and we ensure adherence to local regulations during investigations outside Europe.PerformanceIn 2024, 242 cases reported via the Compliance Hotline relating to accounting issues, fraud and business ethics matters were substantiated. The 9% increase in number of substantiated cases compared to 2023 is driven by the business growth, including increased number of employees. The numbers for 2022 and 2023 have been restated, as cases involving Novo Nordisk Way violations have been moved to table 3.2.5 'Incidents, complaints and severe human rights impacts', where we report on substantiated people-related cases to avoid 'double-counting'.4.1.4 Substantiated cases reported within accounting issues, fraud and business ethics matters Unit 2024 2023 2022Substantiated cases reported within accounting issues, fraud and business 1ethics matters via the Compliance HotlineNumber 242 221 2271. Substantiated cases reported within accounting issues, fraud and business ethics matters was previously reported as Number of substantiated cases reported via the Compliance Hotline. For 2023 and 2022, 314 and 288 cases have been reported, respectively, considering the previous definition.ACCOUNTING POLICIESSubstantiated cases reported within accounting issues, fraud and business ethics matters via the Compliance HotlineNumber of cases reported to the Compliance Hotline, where reported allegations of suspected misconduct have been substantiated or partially substantiated. When a case has been substantiated or partially substantiated, corrective actions are initiated.Management of relationships with suppliersPoliciesPolicy Global procurement policyPurpose Ensure good conduct in how we source goods and services, select suppliers and negotiate agreementsScope All sourced goods and services, excluding those used for manufacturing of Novo Nordisk productsMost senior level Corporate vice president of CorporateaccountableProcurementAvailability Externally available: Procurement in Novo NordiskApplicability across ⢠Business conduct, p. 90Sustainability statementSupporting policy ⢠Internal standard operating procedure on documentationprocurement for manufacturingWe are dependent on our suppliers and aim to ensure good conduct in how we source goods and services, select suppliers and negotiate agreements, including fair and transparent payment practices. Our procurement policy defines the guidelines for contracting with us, including qualification and tendering to issuinginvoices and using a spend management platform. The policy applies to our largest sourcing group, indirect spend, but does not apply to goods and services used in the manufacturing of Novo Nordisk's products. In those circumstances, aninternal standard operating procedure supplements the policy.We continue to conduct regular supplier audits, including re-visits, to ensure high quality with the suppliers with which we engage. The risk-based minimum frequencies for quality audits are governed through our procurement for manufacturing setup and the frequencies are based on usage (categories for goods and services). For responsible sourcing audits, we are considering risk parameters such as country of operation and spend.We make procurement decisions that are financially, environmentally and socially responsible as outlined in our Responsible Sourcing Standards in section3.3 âWorkers in the value chainâ on page 88. We use e-sourcing and e-auction solutions to provide faster tendering and ensure a fair and transparent process during negotiations. We work with preferred suppliers to help us build better relationships. Becoming a preferred supplier is dependent on many factors, including openness to continuous improvement and innovation, and delivering quality products in a timely manner.Our standard payment terms are 60 days, but other terms may be agreed as part of contract negotiations. We are committed to preventing late payments to suppliers, particularly when these are small enterprises. During the COVID-19 pandemic, to mitigate the impacts of the crisis, we implemented a payment guideline, that ensured payment to small suppliers as soon as possible upon receipt and approval of invoices (which may have been earlier than the terms specified in invoices or contracts). This guideline was then made permanent and continues to apply today.PerformanceIn 2024, new metrics on payment practices were implemented for the first time.4.1.5 Payment practices Unit 2024 20232022Average number of days to pay invoice Days 42 ââ⢠Small suppliers Days 24 â â⢠Large suppliers Days 49 â âPercentage of payments aligned with standard payment terms % 83 â â⢠Small suppliers % 77 â â⢠Large suppliers % 84 â âOutstanding legal proceedings for late payments Number 0 â âWe continued to increase the number of supplier audits to 429 in 2024 from 382 in 2023, reflecting the increased activity level in Novo Nordisk. Three critical findings were issued during 2024. Two of these were related to responsible sourcing, concerning management of contract labour, for which the remediation is still ongoing. The last finding was related to quality audits, concerning protection against cross contamination, and agreements regarding actions to address it have been made with the affected supplier.4.1.6 Supplier audits Unit 2024 2023 2022Total supplier audits Number 429 382294ACCOUNTING POLICIESAverage number of days to pay invoiceAverage number of days it takes Novo Nordisk to settle an invoice from the invoice date (when contractual or statutory term of payment starts to be calculated) until the invoice has been cleared. Percentage of payments aligned with standard payment termsIncludes all transactions where the invoice cycle time is equal to or less than the specified payment terms, divided by the total number of transactions. Small suppliers (with less than DKK 1 million in spend over the last twelve months) are measured based on 30-day payment terms, whereas other suppliers are assessed using payment terms from the invoice document recorded in our internal systems.Number of outstanding legal proceedings for late paymentsNumber of all outstanding legal proceedings (litigation or arbitration) for late payment.Supplier auditsTotal number of supplier audits, concluded by Novo Nordisk's Corporate Quality & Inspections function, consisting of the number of responsible sourcing audits and quality audits conducted at suppliers, selected using various risk parameters. Audits for responsible sourcing are conducted according to Novo Nordisk's Responsible Sourcing Standard to ensure compliance. In addition, suppliers of goods and services used in the manufacture of Novo Nordisk pharmaceuticals are subject to extensive quality audits in accordance with different quality standards, including third-party audits.Political influence and lobbying activitiesPoliciesNovo Nordisk actively engages with various stakeholders, including public officials, to advocate for important issues affecting patients, our business, our partners and the communities in which we operate globally. Our OneCode policy sets out the objectives of having patientsâ interests as our first priority, acting with professionalism and integrity and adhering to local regulation on public engagement. It also outlines our zero-tolerance of giving or offering anything of value to a politician, public official or decision-maker to seek undue influence. This is essential for us and guides our interactions.Our advocacy is grounded in realising the potential that innovation in our industry can bring to patients, healthcare systems and society, while ensuring transparency and adherence to business ethics in our interactions. We strive to achieve this by advocating for industry-level initiatives and regulation that promote the following:⢠Evidence-based chronic disease prevention, public health and improvement of care for people living with serious chronic diseases.⢠Innovation and provision of optimal conditions for making new discoveries to benefit patients.⢠Improvements of resilience of healthcare systems.⢠A more environmentally sustainable way of operating in the pharma industry.We are a member of various industry and trade associations representing the pharmaceutical industry, to bring about consensus on broad policy issues that affect the patients we serve and our business. Our membership of these organisations is evaluated on an ongoing basis, considering their expertise in policy, advocacy and ability to drive the agenda on issues important to us.To ensure transparency around our activities, we are registered in the EU Transparency Register under ID 29570313329-11. No members of our Board of Directors have held a comparable position in public administration in the two years preceding their appointment.ActionsThrough our engagement with various stakeholders, such as industry and tradeassociations, we have taken actions for the implementation of our objectives, with the key objectives listed in following the table. Unless otherwise indicated, actions are considered recurring.PerformanceIn 2024, a new metric on trade association membership fees was introduced. A zero-tolerance policy applies at Novo Nordisk with regards to in-kind political contributions.4.1.7 Trade association membership fees and in-kind political contributions Unit 2024 2023 2022Trade association membership fees mDKK 177 ââIn-kind political contributions made mDKK 0 ââACCOUNTING POLICIESTrade association membership feesThe total monetary value of trade association membership fees during the financial year reported in DKK millions. Data is collected at country level for Brazil, Canada, China, Denmark, France, Germany, India, Italy, Japan, the United Kingdom and the US, where Novo Nordisk focuses its public affairs activities. In-kind political contributionsIn-kind contributions can include advertising, use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for office.Key actions to address advocacy Presidency of the European Federationof Pharmaceutical Industries and Associations (EFPIA)Obesity advocacy Diabetes advocacy Description and year of completionNovo Nordiskâs President and CEO Lars Fruergaard Jørgensen is President of EFPIA 2023-2025, focusing on the review of the EU General Pharmaceutical Legislation, advocating for innovation and providingoptimal conditions for making new discoveries accessible to patients.Advocacy through EFPIA Obesity Policy Platform to improve healthcare solutions for people living with obesity, recognise obesity as a relapsing chronic disease and increase knowledge of its financial cost.Recurring collaboration with EFPIA Health Systems Working Group, to address some of the major challenges facing health system resilience.Advocacy through the European Diabetes Forum for policy change that enables healthcare systems to better manage diabetes care.Scope of actionPatients in EuropePatients in EuropePatients in EuropeTarget in placeNo No No Overall progress in 2024 and how we track effectiveness⢠Our CEO's presidency of EFPIA supported the collaboration with policy makers, to establish industrial policies aimed at fostering an ecosystem that encourages innovation and prioritises life sciences as a strategic industry.⢠In 2024, Novo Nordisk joined the newly established Obesity Policy Platform.⢠The Health Systems Working Group has made progress on improving efficiencies between health system resources and fostering collaboration on creating more sustainable health systems.⢠Campaigned, together with the European cardiovascular community, for cardiovascular disease and diabetes within European policy priorities.BioethicsPoliciesPolicy Bioethics policyPurpose Guide bioethical behaviour in our research and developmentScope Applies globallyMost senior level Executive managementaccountableAvailability Externally available: BioethicsApplicability across ⢠Business conduct, page 90Sustainability statement⢠Patient protection and quality of life, page 71Supporting policy ⢠Position papers (for each bioethical focus area)documentation⢠Standard operating proceduresBioethics refers to all ethical issues related to the use of life science technologiesfor the discovery, development and production of pharmaceutical products. Novo Nordiskâs bioethics policy sets out general operational guidelines for research and development and informs day-to-day business decisions.Our policy states our commitment to high global ethical standards in research involving people, animals, human materials and gene technology. We extend these requirements to our external partners, contract research organisations and suppliers, and monitor their performance. We act in accordance with relevant international conventions and standards, and actively promote bioethical awareness at Novo Nordisk. We implement the policy objectives by integrating these in standard operating procedures, processes and decision-making, and we have cross-functional governance that addresses emerging bioethical dilemmas. On an annual basis we define strategic focus areas, and report to the leadership teams of Research and Early Development, and Development, on the bioethical strategy execution, highlighting potential bioethical issues.Our policy commitments are further detailed in position statements for specific bioethical focus areas, including clinical trial and human biosample ethics, animal ethics, cell and gene therapy ethics and gene technology ethics, which are all publicly available on our website.Animal welfarePoliciesIt is not currently possible to examine the complex interactions in a living organism using only methods that do not involve animals, such as in silico methods, cell cultures and tissues. Therefore, research involving living animals remains crucial in the discovery, development and production of new pharmaceutical products, to ensure that our products meet high quality and safety standards throughout their life cycle.Novo Nordiskâs bioethics policy, with reference to animal ethics, sets out our high ethical and welfare standards and applies to all animals purchased for research undertaken by us either in-house or by external contractors. The policyincludes animal ethics principles that we uphold, namely: Replace, Reduce and Refine (3Rs) research when using animals, defines practices related to housing, husbandry, care and transportation of animals, and their health control, and thereby ensures that every precaution is taken to reduce suffering and distress.Following the principles of the 3Rs, we continually strive to reduce the number of animals used and to replace animal testing with in vitro methods. We approach the use of non-human primates with care and consideration, only using them when absolutely necessary for efficacy and safety prior to testing in humans, for example when testing potential new therapies where homology to the human genome is essential.We have various channels for the expression of any concerns, such as via the attending veterinarian, the local Animal Unit Manager or the Ethical Review Council, an internal group established to ensure the ethical review of all experiments on living and sentient animals performed at, or on behalf of, Novo Nordisk.Novo Nordiskâs animal rights principles as set out in our bioethics policy comply with the Council of Europeâs Convention for the Protection of Vertebrate Animals used for Experimental and Other Scientific Purposes, forming the basis for Directive 2010/63/EU, which is focused on the protection of animals used for scientific purposes. Novo Nordisk is also a signatory to the Marseille Declaration, establishing, together with our pharmaceutical peers, the worldwide implementation of high standards for animals housed and used internally and externally by the industry for scientific purposes. We continue to engage in discussion on animal ethics and welfare issues, gaining insights from stakeholder2dialogues collaborations with animal welfare organisations, regulators, researchers, students and journalists. PerformanceThe number of animals purchased for research in 2024 decreased by 13% compared to 2023. 96% of the animals were rodents. The decrease is due to our continuous efforts to reduce the number of animals used in research. It also reflects the nature and maturity of the research projects, where species qualification determines the number needed for testing in non-human primates (decreased by 55% from 2023). The significant decrease in the number of fish since 2022, to none in 2024, is due to specific research projects using fish larvae that have been discontinued.4.1.8 Animals purchased for research Unit 2024 20232022Mice, rats and other rodents Number 47,478 54,410 63,760Pigs Number 615 608 427Rabbits Number 689 289 606Dogs Number 126 356 146Non-human primates Number 366 807 700Fish Number 0 36 14,098Other vertebrates Number 10 2 13Total animals purchased Number 49,284 56,508 79,750ACCOUNTING POLICIESAnimals purchased for researchNumber of animals purchased for all research undertaken by Novo Nordisk, either in-house or by external contractors. It is based on internal registration of purchased animals and yearly reports from external contractors.2. These include the Danish Animal Welfare Society, the UKâs Royal Society for the Prevention of Cruelty to Animals, the Danish Association of the Pharmaceutical Industry and the Universities Federation for Animal Welfare.5. AppendixTables in accordance with ESRS 2 General Disclosures and the EU Taxonomy Regulation:Table 1 â Other legislationThe table below includes all of the data points that derive from other EU legislation as listed in ESRS 2 appendix B, indicating were the data points can be found in our report and which data points are assessed as not applicable to Novo Nordisk. Benchmark EU Climate Disclosure SFDR Pillar 3 regulation Law requirement Data pointreferencereferencereferencereference Section PageESRS 2 GOV-1 21 (d) x x Sustainability statement 87ESRS 2 GOV-121 (e)xSustainability statement42-44ESRS 2 GOV-430xSustainability statement49ESRS 2 SBM-140 (d) ixxxNot applicable to NN-ESRS 2 SBM-140 (d) iixxNot applicable to NN-ESRS 2 SBM-140 (d) iiixxNot applicable to NN-ESRS 2 SBM-140 (d) ivxNot applicable to NN-ESRS E1-114xSustainability statement55ESRS E1-116 (g)xxSustainability statement55ESRS E1-434xxxSustainability statement55, 57, 58ESRS E1-538xSustainability statement58, 59ESRS E1-537xSustainability statement58, 59ESRS E1-540-43xSustainability statement58ESRS E1-644xxxSustainability statement58ESRS E1-653-55xxxSustainability statement58ESRS E1-756xNot applicable to NN-ESRS E1-966xNot applicable to NN-ESRS E1-966 (a); 66 (c)xNot applicable to NN-ESRS E1-967 (c)xNot applicable to NN-ESRS E1-969xNot applicable to NN-ESRS E2-428xNot applicable to NN-ESRS E3-19xSustainability statement66ESRS E3-113xNot applicable to NN-ESRS E3-114xNot applicable to NN-ESRS E3-428 (C)xSustainability statement66ESRS E3-429xSustainability statement66ESRS 2- IRO 1 - E416 (a) ixNot applicable to NN-ESRS 2- IRO 1 - E416 (b)xNot applicable to NN-ESRS 2- IRO 1 - E416 (c)xSustainability statement67ESRS E4-224 (b)xSustainability statement67ESRS E4-224 (c)xNot applicable to NN-Benchmark EU Climate Disclosure SFDR Pillar 3 regulation Law requirement Data pointreferencereferencereferencereference Section PageESRS E4-224 (d)xSustainability statement67ESRS E5-537 (d)xSustainability statement62, 63ESRS E5-539xSustainability statement62, 63ESRS 2- SBM 3 - S114 (f)xSustainability statement80ESRS 2- SBM 3 - S114 (g)xSustainability statement80ESRS S1-120xSustainability statement80, 81ESRS S1-121xSustainability statement81ESRS S1-122xSustainability statement81ESRS S1-123xSustainability statement83, 84ESRS S1-332 (c)xSustainability statement81ESRS S1-1488 (b), 88 (c)xxSustainability statement84, 85ESRS S1-1488 (e)xNot applicable to NN-ESRS S1-1697 (a)xxSustainability statement87ESRS S1-1697 (b)xSustainability statement87ESRS S1-17103 (a)xSustainability statement83ESRS S1-17104 (a)xxSustainability statement83ESRS 2- SBM 3 - S211 (b)xSustainability statement88ESRS S2-117xSustainability statement88, 89ESRS S2-118xSustainability statement88ESRS S2-119xxSustainability statement88ESRS S2-119xSustainability statement88ESRS S2-436xNot applicable to NN-ESRS S3-116xNot applicable to NN-ESRS S3-117xxNot applicable to NN-ESRS S3-436xNot applicable to NN-ESRS S4-116xSustainability statement72ESRS S4-117xxSustainability statement72ESRS S4-435xNot applicable to NN-10 (b)ESRS G1-1xNot applicable to NN-ESRS G1-110 (d)xNot applicable to NN-ESRS G1-424 (a)xxSustainability statement91ESRS G1-424 (b)xSustainability statement91Table 2 â Disclosure requirements in ESRS covered by the Sustainability statement ESRS 2 â General disclosures Disclosure requirement Page BP-1: Basis for preparation 49 BP-2: Specific circumstances 49GOV-1: Governance roles 50, 51 GOV-2: Governance 50, 51 GOV-3: Incentives schemes 50-52, 55 GOV-4: Due diligence 49 GOV-5: Risk management 51 SBM-1: Value chain 49, 52 SBM-2: Stakeholders 51SBM-3: Strategy 52IRO-1: Processes 52, 53 IRO-2: ESRS DR's covered 95, 96 ESRS E1 â Climate changeDisclosure requirement Page ESRS 2 GOV-3: Governance 51, 96 E1-1: Transition plan 57 ESRS 2 SBM-3: Strategy 55 ESRS 2 IRO-1: Processes 52-54E1-2: Policies 55 E1-3: Actions 55, 56 E1-4: Targets 56, 57 E1-5: Energy consumption 58, 59 E1-6: Scopes 1, 2, and 3 57, 58 E1-7: GHG removals 57 E1-8: Internal carbon pricing N/A E1-9: Financial effects N/A ESRS E2 â PollutionDisclosure requirement PageESRS 2 IRO-1: Processes 52, 53, 64E2-1: Policies 64E2-2: Actions 64E2-3: Targets 64E2-4: Pollution N/AE2-5: Substances 64, 65E2-6: Financial effects N/AESRS E3 â Water and marine resourcesDisclosure requirement PageESRS 2 IRO-1: Processes 52, 53, 65E3-1: Policies 66 E3-2: Actions 66 E3-3: Targets 66E3-4: Water consumption 66, 67E3-5: Financial effects N/AESRS E4 â Biodiversity and ecosystemsDisclosure requirement PageE4-1: Transition plan 68ESRS 2 SBM-3: Strategy 67ESRS 2 - IRO 1: Processes 52, 53, 67E4-2: Policies 67E4-3: Actions 68E4-4: Targets 68E4-5: Impacts 67, 68 E4-6: Financial effects N/A ESRS E5 â Resource use and circular economyDisclosure requirement PageESRS 2 IRO-1: Processes 52, 53, 60E5-1: Policies 60E5-2: Actions 60, 61E5-3: Targets 61, 62E5-4: Resource inflows 62, 63E5-5: Resource outflows 62, 63E5-6: Financial effects N/AESRS S1 â Own workforceDisclosure requirement PageESRS 2 SBM 2: Stakeholders 51ESRS 2 SBM 3: Strategy 80S1-1: Policies 81, 83, 85S1-2: Processes 80, 81S1-3: Remediate impacts 81S1-4: Actions 81, 84, 86S1-5: Targets 82, 84, 86S1-6: Own employees 82-87 S1-8: Bargaining coverage 82, 83S1-9: Diversity 87S1-10: Adequate wages 82S1-11: Social protection N/AS1-12: Disabilities N/AS1-13:Training N/AS1-14: Health and safety 83-85S1-15: Work-life balance 81, 86S1-16: Compensation 87S1-17: Complaints 83 ESRS S2 â Workers in the value chainDisclosure requirement PageESRS 2 SBM 2: Stakeholders 51ESRS 2 SBM 3: Strategy 88S2-1: Policies 88, 89S2-2: Processes 88S2-3: Remediate impacts 88S2-4: Actions 89S2-5: Targets 89ESRS S4 â Patient protection and quality of lifeDisclosure requirement PageESRS 2 SBM 2: Stakeholders 51ESRS 2 SBM 3: Strategy 71S4-1: Policies 72, 73, 76-79S4-2: Processes 72S4-3: Remediate impacts 72S4-4: Actions 72-74, 76-79S4-5: Targets 72-79ESRS G1 â Business conductDisclosure requirement PageESRS 2 GOV-1: Governance 90ESRS 2 IRO-1: Processes 90G1-1: Corporate culture 90G1-2: Suppliers 92, 93G1-3: Prevention 91G1-4: Incidents 91, 92G1-5: Political influence 93G1-6: Payment practices 92, 93Table 3 â List of incorporations by referenceESRS disclosure requirement ESRS 2 GOV-1 (21 a-e, 23 a, b); G1 GOV-1 (5 a, b): Roles and responsibilities of Board of Directors and Executive ManagementESRS 2 GOV-2 (26 b): Overseeing sustainability mattersESRS 2 GOV-2 (26 a): Sustainability matters discussedESRS 2 GOV-3 (29 a-e): Incentive schemes dependent on sustainability-related targets and performance metricsESRS E1, 13 (related to ESRS 2 GOV-3): Portionof total expensed remuneration to registered executives dependent on performance againstclimate related targets; ESRS 2 GOV-3 (29 d): Portion of total expensed variable remuneration to registered executives dependent on performance against ESG related targetsESRS 2 SBM-1 (42 a-c): Business model and value chainESRS 2 BP-2 (12): Forward-looking informationESRS 2 SBM-1 (40 a, e-g): Sustainability-related goals, significant products, value chainESRS E1-1 (disclosure requirement related toESRS 2 IRO-1 20 b, c): Process to identify andassess climate-related risksESRS S4-4 MDR-A (33b): Overview of what action is planned or underway to pursue material opportunities for the undertaking in relation to consumers and/or end-usersESRS 2 MDR-P (65a): The Novo Nordisk Way EssentialsIncorporation by referenceSee Annual review, subheading âCompetences' on pages 42 and 43 and section 'Independence and meeting attendance overview' on page 44 (and as additional reference within the Sustainability statement: see table 3.2.7 'Diversity metrics â Management levels' on page 87).See Corporate governance report, page 4, sub-section âStrategyâ and Annual review: page 39, sub-sections âAccess and affordabilityâ, âEnvironmental impactâ and âEthics and complianceâ.See Corporate governance report, page 4, sub-section âStrategyâ.See Remuneration report, pages 13-16, 3.5 âShort-term incentive programme 2024â and pages 16-19, 3.6-3.8 âLong-term incentive programmes 2022, 2023 and 2024 â programme designâ; page 5, table 1, rows: Short-term cash-based incentive programme and Long-term share-based incentive programme for the Board of Directors; and page 9, table 7, rows: Short-term incentive programme (STIP) and Long-term incentive programme (LTIP) for Executive Management.See Remuneration report, page 20, table 25.See Annual review, page 9, illustration of the stages from resources to patients.See Annual review, page 35, section âFinancialsâ, sub-chapter 'Forward-looking statements' for information on forward-looking information such as targets.See Annual review, section 'Purpose and sustainability', pages 12-16, for more on our strategy that relate to sustainability matters (and as additional reference within the Sustainability statement: See page 82, table 3.2.3 'Employees and employee turnover').See Annual review, section âRisk managementâ on page 39 with regards to the main strategic risk 'environmental impact'.See Annual review, section 'Innovation and therapeutic focus', page 17-25, for an overview of opportunities to accelerate healthcare innovation across Obesity, Diabetes, Rare Diseases and Cardiovascular & Emerging Therapy Areas.See Annual review, page 15, visualisation âThe Novo Nordisk Way Essentialsâ.Tables 4a â Proportion of Turnover from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024Financial year 2024 2024 Substantial contribution criteriaDNSH criteria (âDoes Not Significantly Harmâ) Proportion of Taxonomy-aligned (A.1.) or -eligible Proportion Climate Climate Climate Climate (A.2.) Category Category of turnover, change change Circular change change Circular Minimum turnover, enabling transitional CodeTurnover2024 mitigation adaptation WaterPollution economy Biodiversity mitigation adaptation Water Pollution economy Biodiversity safeguards 2023 activity activity Economic activities (1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)(13)(14)(15)(16)(17)(18)(19)(20)mDkk % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1. Environmentally sustainable activities (Taxonomy-aligned)Turnover of environmentally sustainable activities (Taxonomy-aligned) (A.1) 0 0% 0% 0%Of which enabling 0 0% 0% 0% 0% 0% 0% 0% 0%Of which transitional 0 0% 0% 0%A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/ELManufacture of medicinal products PPC 1.2 290,403 100% N/EL N/EL N/EL EL N/EL N/EL 100%Turnover of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2.) 290,403 100% 0% 0% 0% 100% 0% 0% 100%Turnover of Taxonomy-eligible activities (A.1. + A.2.) 290,403 100% 0% 0% 0% 100% 0% 0% 100%B. TAXONOMY-NON-ELIGIBLE ACTIVITIESTurnover of Taxonomy-non-eligible activities (B) 0 0%TOTAL 290,403 100%Y â Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective N â No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective N/EL â Not eligible, Taxonomy-non-eligible activity for the relevant environmental objectiveTables 4b â Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024Financial year 2024 2024 Substantial contribution criteria DNSH criteria ("Does Not Significantly Harm") Proportion of Taxonomy-aligned (A.1.) or eligible Proportion Climate Climate Climate Climate (A.2.) Category Category of CapEx, change change Circular change change Circular Minimum CapEx, enabling transitional Code CapEx2024mitigation adaptation Water Pollution economy Biodiversity mitigation adaptation WaterPollution economy Biodiversity safeguards 2023 activity activity Economic activities (1)(2)(3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) mDkk % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1. Environmentally sustainable activities (Taxonomy-aligned)Construction on new buildings CCM 7.1 3,494 3% Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0%CapEx of environmentally sustainable activities (Taxonomy-aligned) (A.1) 3,494 3% 3% 0%Of which enabling 0 0% 0% 0% 0% 0% 0% 0% 0%Of which transitional 0 0% 0% 0%A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/ELConstruction on new buildings CCM 7.1 13,050 11% EL N/EL N/EL N/EL N/EL N/EL 14%Renovation of buildings CCM 7.2 2,336 2% EL N/EL N/EL N/EL N/EL N/EL 5%Manufacture of medicinal products PPC 1.2 20,142 16% N/EL N/EL N/EL EL N/EL N/EL 41%CapEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2.) 35,528 29% 13% 0% 0% 16% 0% 0% 60%CapEx of Taxonomy-eligible activities (A.1. + A.2.) 39,022 32% 16% 0% 0% 16% 0% 0% 60 %B. TAXONOMY-NON-ELIGIBLE ACTIVITIESCapEx of Taxonomy-non-eligible activities (B) 84,950 68%TOTAL 123,972 100%Y â Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective N â No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective N/EL â Not eligible, Taxonomy-non-eligible activity for the relevant environmental objectiveTables 4c â Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024Financial year 2024 2024 Substantial contribution criteriaDNSH criteria (âDoes Not Significantly Harmâ) Proportion of Taxonomy-aligned (A.1.) or -eligible Proportion Climate Climate Climate Climate (A.2.)Category Category of OpEx, change change Circular change change Circular Minimum OpEx, enabling transitional Code OpEx2024mitigation adaptation Water Pollution economy Biodiversity mitigation adaptation Water Pollution economy Biodiversity safeguards 2023 activity activity Economic activities (1)(2)(3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) mDkk % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1. Environmentally sustainable activities (Taxonomy-aligned)OpEx of environmentally sustainable activities (Taxonomy-aligned) (A.1) 0 0% 0% 0%Of which enabling 0 0% 0% 0% 0% 0% 0% 0% 0%Of which transitional 0 0% 0% 0%A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/ELManufacture of medicinal products P 1.2 1,919 5% N/EL N/EL N/EL EL N/EL N/EL 5%OpEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2.) 1,919 5% 0% 0% 0% 5% 0% 0% 5%OpEx of Taxonomy-eligible activities (A.1. + A.2.) 1,919 5% 0% 0% 0% 5% 0% 0% 5%B. TAXONOMY-NON-ELIGIBLE ACTIVITIESOpEx of Taxonomy-non-eligible activities (B) 38,014 95%TOTAL 39,933 100%Y â Yes, Taxonomy-eligible and Taxonomy-aligned activity with the relevant environmental objective N â No, Taxonomy-eligible but not Taxonomy-aligned activity with the relevant environmental objective N/EL â Not eligible, Taxonomy-non-eligible activity for the relevant environmental objective</mrv:SustainabilityReport>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx-1" id="s10__8__32-1" xml:lang="en">2.6 EU TaxonomyThe EU Taxonomy provides a classification system that defines which economic activities are environmentally sustainable, while meeting standards for human rights, anti-corruption, fair competition and taxation. Novo Nordisk welcomes the introduction of comparable sustainability definitions and is working to incorporate relevant EU Taxonomy criteria into our operations to support our sustainability ambitions.The Taxonomy-related disclosure process can be broken down into three major steps. ⢠The first step is a screening of potentially eligible economic activities (screeningin accordance with the technical annexes of the Climate Delegated Act: Annex 1on Climate change mitigation and Annex 2 on Climate change adaptation and ascreening of the Environmental Delegated Act: Annex I on Sustainable use and protection of water and marine resources, Annex II on Transition to a circular economy, Annex III on Pollution prevention and control and Annex IV on Protection and restoration of biodiversity and ecosystems), which results in an already shortened list.⢠In the next step, each of the economic activities are assessed against how Novo Nordisk performs the activity, considering a financial and strategic materiality. This is followed by the detailed assessment of the alignment of identified economic activities, comprising substantial contribution, 'Do No Significant Harm' (DNSH) and minimum safeguards. ⢠Finally, the KPIs required for Taxonomy reporting are extracted (see Novo Nordisk adjusted tabular overview on the next page and the detailed mandatory reporting templates in section 5, tables 4 a-c on pages 97-99). Taxonomy-eligibility Based on our annual review process and materiality considerations, the following economic activities defined in the EU Taxonomy have been identified as relevant to Novo Nordisk:⢠P1.2: Manufacture of medicinal products (environmental objective Pollution prevention and control) - relevant for the Turnover, CapEx and OpEx KPIs (eligibility).⢠CCM7.1: Construction of new buildings (environmental objective Climate change mitigation) - relevant for CapEx (eligibility and alignment).⢠CCM7.2: Renovation of existing buildings (environmental objective Climate change mitigation) - relevant for CapEx (eligibility).Taxonomy-alignment â Substantial contribution and 'Do No Significant Harm' (DNSH)Novo Nordisk has assessed the technical screening criteria for eligible economic activities deemed material and has conducted an internal analysis of the feasibility of Taxonomy-alignment. This leads to the following result for 2024: ⢠7.1 Construction of new buildings: An evaluation of the Climate Delegated Act Annex 1 on climate change mitigation has been conducted, leading to the conclusion that alignment of new building construction can be claimed following a positive gap analysis. A proportion of two major ongoing construction projects in Hillerød and Kalundborg, Denmark, have met the requirements of Taxonomy- alignment. These projects demonstrate compliance with a substantial number of the technical screening criteria for 2024. Certain criteria are yet to be fulfilled because the relevant construction phase has not been reached. We assume fulfilment of these on the basis of pre-calculations in the design phases, robust processes, and controls throughout the entire construction process. We thereby claim alignment based on the expectations that our construction continues to follow our plans. As part of Novo Nordisk's commitment to expanding production capacity in a sustainable way, future building projects will incorporate alignment criteria when feasible in the upcoming years.⢠7.2 Renovation of existing buildings: This economic activity represents the second phase in implementing Taxonomy-alignment within our construction and real estate activities. No alignment is reported for this activity in 2024.⢠1.2 Manufacture of medicinal products: We are also conducting an initial assessment of alignment criteria focused on our Danish manufacturing sites ®®for Ozempic and Wegovy for economic activity 1.2. We currently meet many of the criteria, such as using readily biodegradable ingredients in our medicinal products and managing emissions of pollutants to air, water, and soil. However, we have encountered challenges in obtaining evidence for, or addressing the practical aspects of, meeting some of the criteria, which will require further consideration in alignment with our Circular for Zero strategy.Taxonomy-alignment â Minimum safeguardsOperating as a responsible business is a core value for Novo Nordisk, including meeting the minimum safeguards defined in the EU Taxonomy through the following practices:⢠Commitment to respecting human rights across our value chain. Our human rights due diligence process is aligned with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises (see section 3.3 'Workers in the value chain' on page 89).⢠Strict prohibition of bribery and corruption, and adherence to relevant laws and industry codes. Our robust anti-corruption programme comprises internal audits, training for employees and business partners as well as due diligence around third-party representatives (see section 4.1 'Business conduct' on page 91).⢠Managing our tax affairs responsibly, while complying with both the letter and spirit of the law. We are committed to tax transparency and comply with applicable tax regulations.⢠Valuing fair competition and complying with laws governing relationships with suppliers, customers, and competitors. Employee awareness of competition laws is promoted, and all business practices are aligned with these regulations.1Novo Nordisk adjusted EU Taxonomy overview1(see section 5, tables 4 a-c for the mandatory reporting templates)Turnover CapExOpEx2024 2024 2024Environmental objective Economic activity (mDKK) (%) (mDKK) (%) (mDKK) (%)Total Turnover, CapEx, OpEx 290,403 100 57,720 100 39,933 100Taxonomy-non-eligible activities 0 0 18,698 32 38,014 95Climate change mitigation 7.1 Construction of new buildings 0 0 13,050 23 0 07.2 Renovation of existing buildings 0 0 2,336 4 0 0Pollution prevention and control 1.2 Manufacture of medicinal products 290,403 100 20,142 35 1,919 5Eligible not aligned 290,403 100 35,528 62 1,919 5Eligible and aligned7.1 Construction of new buildings (in Hillerød and Kalundborg, Denmark) 0 0 3,494 6 0 01. Excluding impact of Catalent acquisition. With the inclusion of Catalent, total CapEx would have been DKK 123,972 million, eligible not aligned CapEx 29% and eligible and aligned CapEx 3%.Contextual information about the KPIsIn 2024, no additional economic activities were added to the reporting scope and no changes were made to the data collection process. As a result of our Taxonomy screening process:⢠Turnover in 2024 was 100% Taxonomy-eligible, but 0% Taxonomy-aligned.⢠CapEx in 2024 was 68% Taxonomy-eligible (32% including Catalent), hereof6% eligible and aligned (3% including Catalent) under economic activity 7.1'Construction of new buildings'.⢠OpEx in 2024 was 5% Taxonomy-eligible, but 0% Taxonomy-aligned. We consider all Novo Nordiskâs turnover Taxonomy-eligible under economic activity 1.2. Taxonomy-eligible CapEx includes only CapEx directly associated with the manufacturing process or related to construction or renovation of buildings; intangible assets are therefore excluded. This is the main reason for reported Taxonomy-eligibility under economic activity 1.2 being less than 100%. Eligible CapEx mainly relates to the expansion of production capacity and additions to property, plant and equipment, as per note 3.2 'Property, plant and equipment' on page 115 in the Consolidated financial statements. Eligible OpEx includes R&D directly linked to the manufacturing processes. As a result, only R&D costs from Chemistry, Manufacturing and Control Development & Scaling (CMC) are counted as Taxonomy-eligible OpEx. Taxonomy reporting templates in accordance with Article 8 of Commission Delegated Regulation (EU) 2021/2178, as amended by the Taxonomy Environmental Delegated Act (Commission Delegated Regulation (EU) 2023/2486) can be found in section 5, tables 4 a-c.We do not carry out any activities relating to the generation of nuclear energy and fossil gas as per delegated regulation 2022/1214 and hence consider these economic activities not applicable. Novo Nordisk purchases fossil gas for own production processes (see section 2.1 'Climate change' for further details).Moreover, the EU Taxonomy Regulation and the related Delegated Acts contain formulations and terms that are still subject to considerable interpretation uncertainty and for which clarifications have not yet been published in every case. Due to the inherent risk that undefined legal terms can be interpreted differently, the legal compliance of the interpretation is subject to uncertainty (we refer to the section 'Forward-looking statements' on page 35 for further details).ACCOUNTING POLICIESThe Taxonomy KPIs include all fully consolidated companies of the Novo Nordisk Group. The CapEx resulting from the acquisition of Catalent in December 2024 (see section 1.2 âBasis for preparation of the Sustainability statementâ on page 49) is recognised accordingly in the Taxonomy tables in section 5 in order to reconcile this with the financial reporting.Total Turnover Total revenue from sale of goods, as defined under IFRS Accounting Standards (see note 2.1 'Net sales and rebates' on page 107 in the Consolidated financial statements). The turnover KPI is defined as Taxonomy-eligible turnover divided by total turnover. Capital expenditures (CapEx)Additions to fixed assets (including finance leases) and intangible assets. Additions resulting from business combinations are also included. Goodwill is not included in CapEx as it is not defined as an intangible asset in accordance with IAS 38. The CapEx KPI is defined