Assets
| Type | Time | Amount | Unit |
|---|---|---|---|
| ifrs-full:Assets | 2024-12-31 | 4989000000 | vDKK |
| ifrs-full:Assets | 2023-12-31 | 3848000000 | vDKK |
Revenue
| Type | Start date | End date | Amount | Unit |
|---|---|---|---|---|
| ifrs-full:Revenue | 2024-01-01 | 2024-12-31 | 9352000000 | vDKK |
| ifrs-full:Revenue | 2023-01-01 | 2023-12-31 | 8338000000 | vDKK |
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<mrv:CorporateGovernanceReport contextRef="ctx1" id="fact2063" xml:lang="en">Corporate Governance  Governance Structure  NTG has a two-tier governance structure comprised of the  Board of Directors and the Executive Management. The ultimate  governing authority rests with the General Meeting.  In terms of internal organisation, the Group Management  comprises the Executive Management, the divisional CEOs, and  the Executive Vice President. The Executive Management is  comprised of the Group CEO and Group CFO, as registered with  the Danish Business Authority.  The Board of Directors is responsible for the overall strategic  management and organisation of the Groupâs activities as well  as the Groupâs financial and material matters. The Board of  Directors has established an audit, a remuneration, and a nomi-  nation committee focusing on preparatory tasks within  the Board of Directorsâ areas of responsibilities.  The Executive Management is responsible for NTGâs day-to-day  management, including the compliance of NTG and its opera-  tions with applicable legislation, the Board of Directorsâ guide-  lines and instructions, including implementation of the strategy  set by the Board of Directors, and for disseminating information  on NTGâs operations to the Board of Directors.  Further allocation of responsibilities between the Board of  Directors and the Group Management is set out in the Rules of  Procedure of the Board of Directors and in a set of management  instructions issued by the Board of Directors to the Group  Management.  Board of Directors  Composition  According to the Articles of Association, the Board of Directors  must comprise not less than three and not more than eight  members elected by the General Meeting for terms of one year.  Board members are eligible for re-election.  No members resigned and no new members were elected to the  Board of Directors in 2024.  The Board of Directors currently comprises seven members  representing strong knowledge and expertise within all areas of  NTGâs business and strategic focus areas, including the interna-  tional transport sector in general, corporate governance, M&A,  risk management, IT, accounting, and supply chain management.  The composition of the Board of Directors is intended to ensure  that the Board is made up by a diverse competency profile  enabling the Board of Directors to perform its duties in the best  possible manner. The current Board of Directors is considered  to have the right competencies supporting the long-term value  creation for NTGâs shareholders. Reference is made to pages  39-40 for an overview of the current board membersâ individual  competencies.  Independence  Six of the seven members of the Board of Directors are regard-  ed as independent, according to the Danish Recommendations  on Corporate Governance. Jørgen Hansen is the founder of NTG  and was, until 2018, a member of the Executive Management in  Nordic Transport Group A/S (the former parent company of the  Group). As a result, he is not regarded as independent according  to the Danish Recommendations on Corporate Governance.  Board meetings in 2024  The Board of Directors held 10 board meetings in 2024.  The agendas and the topics for each of the ordinary meetings  are based on the Board of Directorsâ annual wheel.  In addition to the activities included in the annual wheel, the  Board of Directors focused on supervising NTGâs continuous  adaption to the unstable situation in the international freight  markets in 2024.  Board Committees  The Board of Directors has established three permanent  committees for the purpose of assisting the Board of Directors  in preparing decisions and submitting recommendations for the  entire Board of Directors. Each committee is governed by its  own charter which describes the composition of the committee  and its tasks, duties, and responsibilities. The Board of Directors  takes the final decision on subjects prepared by the committees.  Audit Committee  The Audit Committee comprises three members: Carsten  Krogsgaard Thomsen (Chairman), Eivind Drachmann Kolding,  and Finn Skovbo Pedersen. The Audit Committee meets at least  four times a year.  The composition of the Audit Committee ensures that compe-  tencies and experience within financial accounting and internal  controls are represented. The Committeeâs activities, tasks, and  duties include monitoring of NTGâs financial reporting process,  internal controls, IT, risk management, capital structure, and  ESG and diversity initiatives. The Committee is also responsible  for ensuring independence and remuneration of the elected  external auditor as well as supervising the auditorâs non-audit  services to NTG. The Audit Committee held four meetings in  2024.  Remuneration Committee  The Remuneration Committee comprises three members: Eivind  Drachmann Kolding (Chairman), Jørgen Hansen, and Jesper  Præstensgaard. The Remuneration Committeeâs activities, tasks,  and duties include preparation of the Groupâs Remuneration  Policy in accordance with section 139a of the Danish Compa-  nies Act, proposing remuneration and specific targets (KPIs) for  performance-related incentive programmes and preparation of  the Remuneration Report in accordance with section 139b of  the Danish Companies Act and NTGâs Remuneration Policy. The  Remuneration Committee meets at least twice a year.  The Remuneration Committee held two meetings in 2024.  Nomination Committee  The Nomination Committee comprises three members: Jørgen  Hansen (Chairman), Jesper Præstensgaard and Eivind Drach-  mann Kolding. The Nomination Committeeâs activities, tasks,  and duties include evaluation of the individual board membersâ  competencies, assisting the Chairman of the Board of Directors  in the annual evaluation process, making recommendations for  potential new members to the Board of Directors, reviewing  NTGâs policy on diversity, and assessing the structure, size,  and composition of the Board of Directors and the Executive  Management. The Nomination Committee meets at least twice  a year.  The Nomination Committee held two meetings in 2024.  Board evaluations  The Board of Directors completes annual self-evaluations. In ac-  cordance with the Recommendations on Corporate Governance,  the evaluation focuses, inter alia, on the composition of the  Board of Directors, the competencies of the Board of Directors,  the functioning of the board committees, the efficiency of the  Board of Directors, the individual board membersâ contribu-  tions, and the role of the Chairman and Executive Management.  The Chairman oversees the self-evaluation process and conclu-  sions are presented to and discussed by the Board of Directors.  The results of the evaluation related to the Executive Manage-  ment are reviewed by the Chairman together with members of  the Executive Management.  Recommendations on Corporate Governance  NTG observes the Recommendations on Corporate Govern-  ance. NTG complies with all recommendations and has prepared  the statutory statement on Corporate Governance pursuant to  Section 107b of the Danish Financial Statements Act.  Corporate Governance Report  NTG complies with all recommendations on  Corporate Governance.  </mrv:CorporateGovernanceReport>
<mrv:StatementOfTheDiversityPolicies contextRef="ctx1" id="fact2188" xml:lang="en">Reporting on data ethics and diversity  Information about data ethics and diversity in our parent  company NTG Nordic Transport Group A/S, in accordance with  sections 99d, and 107d of the Danish Financial Statements Act,  can be found on NTGâs website: Data ethics & Diversity report.  </mrv:StatementOfTheDiversityPolicies>
<mrv:StatementOfPolicyForDataEthics contextRef="ctx1" id="fact2197" xml:lang="en">Reporting on data ethics and diversity  Information about data ethics and diversity in our parent  company NTG Nordic Transport Group A/S, in accordance with  sections 99d, and 107d of the Danish Financial Statements Act,  can be found on NTGâs website: Data ethics & Diversity report.  </mrv:StatementOfPolicyForDataEthics>
<mrv:SustainabilityReport contextRef="ctx1" id="fact2214" xml:lang="en">General  information  ESRS 2  Basis for preparation  ESRS 2 BP-1  General basis for preparation of  sustainability statements  The sustainability statement in this yearâs An-  nual Report has been prepared using the same  consolidated basis as NTGâs 2024 financial  statements and covering same period from  1 January 2024 to 31 December 2024. The  consolidated quantitative ESG data comprises  the Parent Company NTG Nordic Transport  Group A/S, and all subsidiaries controlled by  NTG Nordic Transport Group A/S. Acquired  activities in the reporting period is included in  the sustainability reporting from the closing  date of the transaction.  All quantitative ESG data is consolidated  according to the principles outlined above,  unless otherwise specified in the accounting  policy accompanying each reported data point  in the tables within sections Environmental,  Social, and Governance information.  The sustainability statement has been pre-  pared in compliance with the EUâs Corporate  Sustainability Reporting Directive (CSRD) and  the requirements of the European Sustainabil-  ity Reporting Standards (ESRS).  The double materiality assessment process  outlined in IRO-1 contains impacts, risks, and  opportunities throughout our entire value  chain, both upstream and downstream. More  details on NTGâs policies, actions, targets, and  metrics can be found in the sections related  to the topical standards. There are no omitted  disclosures on information corresponding to  intellectual property, know-how or the results  of innovation in the sustainability statement  nor omitted disclosures regarding impending  developments or ongoing negotiations.  ESRS 2 BP-2  Disclosures in relation to specific  circumstances  Key accounting estimates and  judgements  In presenting the 2024 sustainability state-  ment, NTG utilises assessments and estimates  for reporting certain data points where data is  not available. These estimates and assump-  tions are regularly reassessed based on expe-  rience, advancements in ESG reporting, and  various other factors. NTG keeps the same  definition and calculation of metrics over time.  Should any changes in estimates appear they  would be duly recognised in the period when  the revision occurs and restated comparative  figures provided. Additionally, we apply judge-  ments when implementing the accounting  policies. For more detailed information on the  key estimates, judgements, and assumptions  used, please refer to the pages containing the  quantitative ESG data on NTG's Scope 1, 2  and 3 GHG emissions on page 70.  Incorporation by reference  NTG has adopted the ESRS âIncorporation by  Referenceâ approach to enhance the narrative.  As a result, certain disclosure requirements  have been included in other sections of the  Annual Report and thus outside the Sustain-  ability Statement. These disclosure require-  ments include:  · GOV-1 - Information related to disclosure of  permanent committees and composition es-  tablished by the Board of Directors on page  36-38 of the Management Review.  · GOV-1 - Information related to disclosure of  expertise of Board of Directors, included un-  der sections "Relevant Skills and Experience"  subheadings on page 39-40 of the Manage-  ment Review.  · E1-5, E1-6 - Net revenue on p. 20.  Use of phase-in provisions  For the first year of reporting under ESRS, the  transitional provision in ESRS 1, paragraph  137 allowing for phasing-in certain datapoint  disclosures has been applied, more specifically  encompassing E1 (E1-9), and S1 (S1-7, S1-11).  ESRS 2  Sustainability governance  ESRS2 GOV-1  The role of the administrative, management and  supervisory bodies  Governance Structure  NTG has a two-tier governance structure comprised by the  Board of Directors and the Executive Management. The  ultimate governing authority lies with the General Meeting. In  terms of internal organisation, the Group Management consists  of the Executive Management, the divisional CEOs, and the  Executive Vice Presidents. The Executive Management com-  prise of the Group CEO and Group CFO, as registered with the  Danish Business Authority.  The Board of Directors is responsible for the overall strate-  gic management and organisation of the Groupâs activities as  well as the Groupâs financial and material matters. The Board  of Directors has established an audit, a remuneration, and a  nomination committee focusing on preparatory tasks within the  Board of Directorsâ areas of responsibilities (For more details  on the different committees and members, reference is made  to the Corporate Governance statement in the Annual Report  section p. 36-38).  The Executive Management is responsible for NTGâs day-to-day  management, including the compliance of NTG and its opera-  tions with applicable legislation, the Board of Directorsâ guide-  lines and instructions, including implementation of the strategy  set by the Board of Directors, and for disseminating information  on NTGâs operations to the Board of Directors. Further allo-  cation of responsibilities between the Board of Directors and  the Group Management is set out in the Rules of Procedure of  the Board of Directors and in a set of management instructions  issued by the Board of Directors to the Group Management.  Board of Directors - Composition  According to the Articles of Association, the Board of Directors  must comprise not less than three and not more than eight  members elected by the General Meeting for terms of one  year. Board members are eligible for re-election. No members  resigned in 2024 and no new memebers were elected to the  Board of Directors in 2024.  The Board of Directors currently comprises seven members  representing strong knowledge and expertise within all areas  of NTGâs business and strategic focus areas, including the  international transport sector, corporate governance, M&A, risk  management, IT, accounting, and supply chain management.  The composition of the Board of Directors is intended to ensure  that a diverse set of competencies enables the Board to perform  its duties as intended. The current Board of Directors is consid-  ered to have the right competencies supporting the long-term  value creation for NTGâs shareholders. Reference is made to  pages 39-40 for an overview of the current board membersâ  individual competencies.  Sustainability matters  The Board of Directors and Executive Management at NTG are  responsible for establishing the policy, strategy, and objectives  for our sustainability and ESG efforts. They oversee the overall  ESG risks and strategies, including climate-related and other  significant sustainability risks.  The implementation of these strategies and the execution of  agreed activities are delegated to our legal, compliance and ESG  functions, under the supervision of our Group CFO. These func-  tions also work closely with local management when necessary.  They monitor the progress of activities and gather both internal  and external data, with support from other relevant functions  within the Group.  ESRS2 GOV-2  Information provided to and sustainability matters  addressed by the undertaking's administrative,  management and supervisory bodies  The Board of Directors and Group Executive Management are  responsible for setting the NTG Groupâs business strategy and  risk management, including sustainability matters. The Board  is briefed by the Executive Management on NTG Groupâs  approach to sustainability, performance and material impacts,  risks and opportunities during regular updates, and reviews and  approves the annual sustainability report.  The implementation of the strategy and the execution of the  agreed activities are delegated to legal, compliance and ESG  functions in NTG under the supervision of our Group CFO.  NTGâs organisation is characterised by a flat hierarchy with  short lines of communication, meaning that new sustainability  matters quickly reach the Executive Management and can be  managed promptly. Weekly operational and strategic meetings  take place between the CFO and ESG function to discuss the  progress of the implementation of the sustainability work.  At least once a year, the Audit Committee and Board of Direc-  tors are presented with the results of the double materiality  assessment. This presentation includes the method and result of  identified impacts, risks and opportunities deemed material.  Risk assessment is an inherent part of NTGâs recurring strategic  analyses. The Board of Directors is responsible for the overall  risk management of NTG, while the Audit Committee monitors  and evaluates the risk management framework and provides  recommendations to the Board of Directors. The Executive  Management is responsible for the design and maintenance of  the Groupâs risk management process. Sustainability matters  is a part of the risk assessment process in NTG.  ESRS2 GOV-3  Integration of sustainability-related performance in  incentive schemes  NTG has different incentive programmes to the management,  partners and key employees. The short-term incentive program  (STIP) for the Executive management is linked to sustainability  matters or sustainability-related performance, as the only one.  Short-term incentive program (STIP) is an annual cash-based bo-  nus incentive linked to the KPIs for each member of the Execu-  tive Management. There is an KPI related to sustainability which  constitutes to 10% of the STIP. The sustainability KPI includes  various tasks for the Executive management from specific  projects related to reducing emissions from NTGâs operation to  the preparation of reportings on selected sustainability topics  relevant NTG. The Board of Directors evaluates the degree of  the sustainability KPI achievement annually based on recogni-  tion of agreed projects for the period.  ESRS2 GOV-4  Statement on due diligence  See our additional information to the Sustainability Statement  on page 113.  ESRS 2  Risk management and internal controls  in sustainability reporting  ESRS2 GOV-5  NTGâs sustainability reporting is susceptible to the risk of material  misstatement due to human error or incomplete data.  NTGâs sustainability reporting could be at risk  of material misstatement due to human error  or incomplete data. This risk is elevated due  to NTGâs rapid growth through acquisitions,  as newly acquired companies adopt NTGâs  Group-wide systems and processes through-  out the year. NTG has implemented several  processes to mitigate this risk.  The Group CFO is responsible for maintaining  a consolidated data model for the NTG Group,  which is done through a dedicated reporting  software that collects and consolidates all  sustainability data. The process is supported  by internal process, guidelines and control  procedures on how to manage and report  sustainability data.  All data presented in the sustainability state-  ment are described in the accounting policies,  and if estimates are used in the data calcu-  lations, the accounting policy describes how  estimates are accounted for in each data point.  Our process automates data collection, en-  sures full transparency and traceability. It also  standardises terms, formulas, and key varia-  bles such as emission factors, in compliance  with the Greenhouse Gas Protocol (GHG).  Additionally, accounting principles based on  ESRS requirements have been adopted for the  sustainability data presented in the Sustain-  ability Statement. NTGâs external auditor  provides assurance on the sustainability state-  ment in accordance with the requirements  in CSRD and ESRS. For more information,  please refer to the auditorâs limited assurance  statement.  ESRS 2  Strategy and business model  ESRS2 SBM-1  Strategy, business model and value chain  NTG is an asset-light freight forwarder supporting our custom-  ers with transportation and distribution of their goods via our  global network of suppliers. NTG is organised in two divisions  â Road & Logistics and Air & Ocean, with a number of sub-  sidiaries present in more than 25 countries in Europe, North  America and Asia.  NTG serves a range of different companies with their trans-  portation needs, from raw materials to finished goods. NTG  offers customised transport solutions using different means  of transportation and additional related services to meet our  customers' needs.  NTG's main role is to act as a coordinator, planner, and negoti-  ator. We utilise a global network of subcontractors, including  hauliers, shipping companies, and air freight companies, to carry  out the physical transportation. Additionally, NTG provides  logistic services from our own warehouses across Europe and  North America. The total net revenue from NTG's activities in  2024 was DKK 9,352 million.  Within Road & Logistics services, NTG offers tailored road  freight and warehousing solutions across Europe on a broad  range of products, services and verticals such as: full-loads,  part-loads, groupage, oversized cargo, projects, temperature  controlled, high-tech, automotive, powder, recycling, furniture,  textiles, sensitive and regulated goods, dangerous goods, ware-  housing, distribution, customs brokerage and express service.  There are 52 operational subsidiaries in the division spread  across 19 countries with local presence, which comprise 75% of  the Group revenue.  Within Air & Ocean services, NTG offers the entire range of  air and ocean freight services throughout Europe and world-  wide such as: airport-airport, port-port, door-door, less-than-  container-load, full-container-load, buyerâs consolidation,  direct shipments, temperature controlled, customs brokerage,  full-charter, part-charter, onboard courier, dangerous goods,  project transport, and express service. There are 17 operational  subsidiaries in the division spread across 22 countries with local  presence, which comprise 25% of the Group revenue.  Sustainability-related goals  NTG relies on a strong collaboration with our suppliers across  the globe. Together, we deliver sustainable progress and value  to our stakeholders by acting lawfully, respectfully, and respon-  sibly as a corporate citizen, employer, and business partner.  Climate and environment: Reducing the direct and indirect en-  vironmental impact of our activities through our own initiatives  and in our value chain in collaboration with our customers and  subcontractors is paramount to obtaining sustainable progress.  To secure this, we have committed to set our emission reduction  targets in line with the Science Based Targets initiative (SBTi)  to limit global warming to 1.5°C and reach net-zero emissions  by 2050 in line with the most recent climate research and  recommendations and Paris Agreement goals. Achieving such  targets will include collaboration with various partners such as  customers, and suppliers. This is why we have committed to tak-  ing an active role in fostering collaboration with both customers  and suppliers to reduce carbon emissions from our network.  This will be further elaborated in the section of Environmental  and Climate Change (E1) on page 62.  Social: NTG is a peopleâs business that rely on employees thriv-  ing and being inspired from their workplace. We are committed  to having a diverse workforce as we believe it gives a stronger  basis for engaging with our customers. Our employeesâ contin-  ued motivation and health are essential for our achievements.  To ensure a safe workspace, we have established targets for  reducing work-related injuries and lost days due to such injuries.  We also believe that diversity is a source of strength and  innovation for our organisation. To attract and retain talent-  ed employees, we have set targets for the composition of  our workforce. For the Board of Directors, we aim for a 2/7  representation of the underrepresented gender. At other  management levels, including executive management and those  reporting directly to executive management, we aim to achieve  a 10% representation of the underrepresented gender by 2027  at the latest.  Additionally, we have set targets related to diversity. These will  be elaborated in the Social and Employees (S1) section of this  report.  Governance: NTG is committed to complying with all applicable  laws and regulations that govern our business activities. As a  publicly listed company operating in different countries, we face  various legal and regulatory challenges. Moreover, our reliance  on independent carriers exposes us to both internal and exter-  nal compliance risks.  To address these challenges and risks, we have developed a  Legal Compliance Program that covers anti-corruption, foreign  trade controls, competition laws, and data privacy. The program  aims to prevent, detect, and remedy any potential violations  of these laws. Our Code of Conduct outlines our core values,  and it guides us in making ethical and responsible decisions in  our daily work. To ensure that our Code of Conduct and other  elements of our Legal Compliance Program are well understood  and followed by all our employees, we have made online training  a high priority. Therefore, we have set a target that all salaried  employees must receive training in our Code of Conduct every  year, and we will report on our progress annually.  To ensure commitment and compliance from our suppliers, we  have implemented a Code of Conduct for Suppliers that reflect  our commitment to sustainability in areas such as human rights,  anti-corruption, supplier relationships, labour standards, and en-  vironmental responsibility. Here, we are committed to perform  yearly compliance audits and spot checks of suppliers performed  through remote audits, questionnaires, and checklists. We also  conduct internal follow-ups and checks of our own entities. We  are further committed to perform yearly compliance spot checks  of NTG entities to monitor the effectiveness of our mitigating  measures under NTG's Legal Compliance Program. This will be  elaborated in the section of Governance (G1) of this report.  Business model and value chain  NTGâs business model is characterised in line with the gener-  al freight forwarding industry by operating without owning  physical transportation assets (such as ships, planes, or trucks).  Instead, freight forwarders focus on coordinating and managing  logistics services by leveraging existing carrier networks to  strike the right balance between cost, speed, and reliability for  our customers. This business model allows freight forwarders to  remain flexible, cost-efficient, focus on specialised services and  still able to quickly adapt to changing market conditions.  Employees play a crucial role in our operations by communi-  cating with customers to address their service requests and  coordinating with transport suppliers to fulfil these require-  ments. Additionally, our employees manage various administra-  tive and back-office functions that support the business and its  development.  Suppliers provide the physical transport of NTG's customersâ  goods which is why we are highly dependent on our suppliers  and their employees to operate our entire value chain. The  supplier and their employees must be able on behalf of NTG to  handle goods and the transport unit (e.g. trailer or ocean freight  container) and comply with agreed customer-specific quality  criteria and procedures. Additionally, suppliers must be able  to handle and mitigate any deviations that could occur during  a transport in cooperation with NTG, the customer, and other  suppliers in the value chain.  Our flexible model enables us to navigate the supply chain  alongside our customers, regardless of market conditions. Hav-  ing a local presence in the markets where we operate allows us  to act swiftly and appropriately when market conditions change.  This business model enables us to remain flexible, cost-efficient,  and focused on specialised services, while quickly adapting to  changing market conditions. Further, the flexible and transpar-  ent business makes it easier for existing and potential investors  to assess NTG as an investment.  NTG provides end-to-end transport and logistics services,  acting as coordinator, planner, and negotiator. We use a network  of subcontractors to carry out the physical transport on behalf  of our customers. Consequently, the physical transport is con-  ducted throughout both the upstream and downstream value  chains of NTG.  Business and value creation  NTG provides transport solutions by road, rail, air, and ocean, combined  with contract logistics. Our flexible, asset-light business model enables us to  navigate supply chains together with employees and customers, from shipper  to consignee.  ESRS2 SBM-2  Interests and views of stakeholders  NTGâs various stakeholders are essential for our services,  operations and long-term success. By understanding their  perspectives and interests, we can shape our strategy and  business model effectively. This includes developing decar-  bonising solutions and minimising our customersâ supply chain  emissions, fostering a meaningful workplace that supports our  growth strategy, and conducting business with integrity in all  our markets.  We map and describe all of NTGâs key stakeholders and engage  with them on a regular basis, some more often than others.  However, the purpose remains the same: to gather information  on their interests and views on sustainability topics and our  business operations.  Our stakeholdersâ perspective on sustainability helps us lay the  foundation for identification of potential sustainability matters  we identify in our materiality assessment of NTG. This process  is reported in more details in IRO-1 in this report. In table SBM-  2 Interests and views of stakeholders, we disclose our most  important stakeholders, how we engage with them, and what  we gain from the engagement.  NTGâs stakeholders and engagement  ESRS 2 SBM-2  Interests and views of stakeholders  Employees  Organisation of engagement  ·Yearly employee satisfaction survey  ·Daily dialogue between employee and  manager, incl. personal development  ·Employee Health & Safety representative  Purpose of engagements  Employees are the backbone of NTG's  business strategy as a service provider of  transports. It is important to ensure high  job satisfaction and engagement and that is  achieved if employees' perspectives on work-  ing life are included in the way NTG operates.  Examples of outcomes from  the engagements  ·NTG's management obtain relevant and  business critical feedback from employ-  ees on customers, suppliers and business  operations.  ·Adaptation and optimisation of employees  working conditions and possibilities.  ·Improved health and safety performance.  Suppliers  Organisation of engagement  ·Supplier audits  ·Daily operational basis â road suppliers  ·Through partnerships â air and ocean  suppliers  Purpose of engagements  NTG is highly dependent on its suppliers and  its employees for several important opera-  tions in NTG's value chain. The supplier and  its employees must be able on behalf of NTG  to handle goods and the transport unit (e.g.  trailer or sea freight container) and comply  with agreed customer-specific quality criteria  and procedures and the NTG's Supplier Code  of Conduct. In addition, the supplier must be  able to handle and mitigate any deviations in  cooperation with NTG and/or the customer as  well as any other suppliers in the value chain.  Examples of outcomes from  the engagements  ·Compliance of NTGâs Code of Conduct for  Suppliers.  ·Improved health and safety culture.  ·Cooperation with suppliers result in low-  carbon solutions can be offered to NTGâs  customers.  Customers  Organisation of engagement  ·Dialogue on a daily operational basis  ·Accounting teams conduct customer  reviews  ·Dialogue on possibilities for carbon emis-  sion reductions  ·Reporting carbon emissions to customers  Purpose of engagements  NTG's transport services conducts a share  of customers scope 3 GHG emissions that  becomes a disclosure requirement for more  and more customers. Customers demand that  NTG can comply with their ESG policies and  other ESG requirements in connection with  the performance of NTG's services.  Examples of outcomes from  the engagements  ·Dialogue with customers forms the basis  for developing alternative services based  on decarbonising solutions.  ·Decarbonising solutions reduces cus-  tomers supply chain emissions and NTGâs  scope 3 emissions.  Investors, financial  institutions, and financial  analysts  Organisation of engagement  ·On regular announced meetings by NTG  management such as investor calls and  roadshows  ·Requested meetings arranged by investors  Purpose of engagements  The management of NTG communicates  to investors the financial status of NTG,  incl. on the development of NTGs work on  sustainability.  It happens that investors ask for meeting as  they have a wish to get further understanding  e.g. on sustainability issues.  Examples of outcomes from  the engagements  ·Dialogue with this group of stakeholders  provides information to NTG on their  sustainable interests, expectations and  requirements.  ·ESG ratings and basic for improvement  ·Securing financing options  Public authorities  and regulators  Organisation of engagement  ·Regular dialogue on tax, VAT, permits on  customers declarations  ·Indirectly via membership of trade asso-  ciations  Purpose of engagements  NTG follow updates of regulations and legis-  lation issued by public authorities to comply  or advise on compliance for customers and  suppliers.  Examples of outcomes from  the engagements  ·Aligning logistic service model and strat-  egy.  ·Value creation and risk mitigation from  compliance.  ESRS2 SBM-3  Material impacts,  risks and  opportunities and  their interaction  with strategy and  business  Output from the materiality assessment  The European Standards (ESRS) lays out 10 top-  ical standards across Environmental, Social and  Governance topics including sub-topics. Besides  the topical standards, there are two cross-cut-  ting standards â ESRS 1 General principles and  ESRS 2 General disclosures â containing general  requirements and disclosures applicable to all re-  porting companies and considered as the start-  ing point for reporting in compliance with the  CSRD framework. NTG's material topics based  on our 2024 double materiality assessment are  presented in the table on next page.  ESRS topical standards, topics and sub-topics  Environment  ESRS E1 â Climate change  · Climate change adaptation  · Climate change mitigation  · Energy  ESRS E2 â Pollution  · Pollution of air  · Pollution of water  · Pollution of soil  · Pollution of living organisms and food  · Substances of concern  · Substances of very high concern  · Microplastics  ESRS E3 â Water and Marine resources  · Water and Marine resources  · Marine reources  ESRS E4 â Biodiversity and ecosystems  · Direct impact drivers of biodiversity loss  · Impacts on the state of species  · Impacts on the extent and condition of  ecosystems  · Impacts and dependencies on ecosystem  services  ESRS E5 â Circular economy and resource use  · Resources inflows, including resource use  · Resources outflows related to products and  services  · Waste  Social  ESRS S1 â Own workforce  · Working conditions  · Equal treatment and opportunities for all  · Other work-related rights  ESRS S2 â Workers in the value chain  · Working conditions  · Equal treatment and opportunities for all  · Other work-related rights  ESRS S3 â Affected communities  · Communitiesâ economic, social and cultural  rights  · Communitiesâ civil and political rights  · Rights of indigenous peoples  ESRS S4 â Consumers and end-users  · Information-related impacts for consumers  and/or end-users  · Personal safety of consumers and/or end-users  · Social inclusion of consumers and/or end-users  Governance  ESRS G1 â Business conduct  · Corporate culture  · Protection of whistleblowers  · Animal welfare  · Political engagement and lobbying  activities  · Management of relationships with  suppliers including payment practices  · Corruption and bribery  The material impacts, risks and opportunities identified during the materiality assessment described in below table are presented alongside the topical ESRS E1 Climate change,  E2 Pollution, S1 Own workforce, S2 Workers in the value chain and G1 Business conduct in this sustainability statement. The material impacts, risks and opportunities current and  anticipated effects are managed through NTG's strategy and business model. Material impacts, risks and opportunities are managed through specific policies, actions, targets and  metrics which all also are addressed and described further in each topical section in the statement.  Location in  IRO  value chain  Time horizon  ESRS E1 â Climate change  Emissions from value chain operations  NTG arranges low to medium carbon emitting transport  Actual negative  ââ â â  operations performed by suppliers on behalf of customers.  impact  Energy consumption in own operations  NTG's own assets is a consumer of energy  Actual negative  ââ â â  resources in order to perform its services.  impact  Low carbon transports and services  ââ â â  Customer demands for zero/low carbon transports and services.  Opportunity  ESRS E2 - Pollution  Air pollutants  ââ â â  NTG's transport activities via value chain generates  Actual negative  emissions and some of these are also air pollutants.  impact  Location in  IRO  value chain  Time horizon  ESRS S1 - Own workforce  Health and safety  ââ â â  Some groups of employees have a risk of being exposed  Actual negative  to injuries and other health risks in the workplace.  impact  Diversity  ââ â â  Increasing focus on gender diversity and showcasing data on  Risk  a diverse workforce poses a risk to NTG if not complying.  Privacy  ââ â â  In case NTG is unable to protect collected data  Actual negative  from unauthorised access or misuse.  impact  ESRS S2 - Workers in value chain  Health and safety  ââ â â  Protecting workers in value chain against  Actual negative  incidents, injuries and fatalities.  impact  ESRS G1 - Business conduct  Prevention and detection including training  â â  â â â  Despite global anti-corruption laws certain areas of NTG's  Risk  organisation are at higher risk of corruption and bribery as  they operate in countries which have higher risks, including the  use of facilitation payments for permits, cargo clearance etc.  ESRS2 IRO-1  Description of the  processes to identify and  assess material impacts,  risks and opportunities  NTG has for years reported on our identified  environmental and social impacts, but it is the first year  we have assessed our impacts, risks, and opportunities  (IROs) based on a double materiality assessment (DMA)  performed following the requirements as described  in the ESRS regulation. To identify our IROs, we have  used a methodology that can be described as a four-  step model but with an iterative approach when found  relevant during the process.  â¶Step: To identify drivers for our IROs we started analysing  the context of our business.  Here, we looked at a broad range of input factors and mapped  out our business model, value chain including business rela-  tionships, activities, products and services, and geographic  locations, to see how these could affect or are affected by  people and/or the environment. To increase the scope of our  analysis, we also conducted desk research to include input from  our legal landscape and relevant ESG standards, sector-specific  frameworks, research papers, media news, etc.  â·Step: To identify any actual and potential  positive and negative impacts and any risks  and opportunities, we involved relevant  internal subject-matter experts.  These experts, drawn from both business  operations and Group functions, possess  deep industry and operational knowledge  and engage in continuous dialogue with our  affected stakeholders. Additionally, the group  of stakeholders provided valuable insights on  sustainability matters and assisted therefore  in identifying all relevant IROs in this process.  Due to their knowledge and continuous en-  gagement with our stakeholders, they served  as proxies for input from external stakehold-  ers, when relevant. We mapped the identified  IROs to the list of matters presented in ESRS  1, AR 16 and added entity-specific matters, if  relevant.  â¸Step: To identify actual and potential  impacts, both positive and negative, as  well as any risks and opportunities, we  have involved relevant internal subject-  matter experts.  These assessments were conducted in bilateral  meetings. The experts were used as proxies  for input from external stakeholders in this  process, when relevant. Impact materiality  was assessed according to their severity (scale,  Scope and irremediability) and likelihood.  Irremediability was not included for positive  impacts, and likelihood was not included  for actual impacts. Financial materiality was  scored on all risks and opportunities identified  and in accordance with their financial magni-  tude and likelihood of occurrence. We mapped  impacts, assessed risks from dependencies,  and identified opportunities from stakeholder  impacts, such as the demand for zero/low  carbon transports.  A 5-point scale was used to score both impact  materiality and financial materiality, and a total  score was calculated. For risks, we have used  the same approach and scale as for assessment  of risk management in NTG. This prioritizes  sustainability-related risks alongside other  risks in NTG's yearly assessment. NTG view  risks as any adverse event, likely or unlikely,  that may impact the Groupâs business, opera-  tions, financial position, or prospects.  To define materiality, a threshold of above  2.5 was used for both impact materiality and  financial materiality. When the combined score  of the double materiality assessment result is  above 2.5, it is considered a material topic to  NTG.  The final score was derived from a blend of  assumptions, our own data, third-party quan-  titative data (where available and practical),  and qualitative insights from meetings with  both internal and external stakeholders. When  applicable, location-specific factors were  also considered in evaluating the identified  IROs. The assessment process was further  enriched by utilising pre-existing records,  self-assessment results, document analysis,  academic research, and more. Additionally, our  evaluation considered silent stakeholders, such  as nature, through the perspectives of NGOs.  Lastly, the Board of Directors and Group  Executive Management are responsible for  setting the NTG Groupâs business strategy  and risk management, including sustainability  matters. The process and approach for the  DMA and final result of material IROs has been  presented to the Group Executive Manage-  ment and Board of Directors to get their input  and approval.  â¹Step: Based on the result of the list of  material matters for NTG ESRS 2 and the  relevant topical standards were consulted  to assess disclosure requirements and data  points to be used for gap analysis and final  reporting.  The material matters can be found on the  previous page.  Omitted sustainability topics  Some sustainability topics and sub-topics  were deemed immaterial in our process to  identify and assess materiel topics and were  excluded from the review. This includes ESRS  topical standards E3 â Water and marine re-  sources as we do not significantly utilize water  and marine resources in our daily operations,  E4 â Biodiversity and ecosystems as NTG's  efforts in climate change mitigation indirectly  help prevent ecosystem changes caused by  global warming. E5 â Circular economy as  NTGâs operations do not involve any signifi-  cant resource inflows or outflows.  ESRS2 IRO-2  Content index of ESRS disclosure requirements  Disclosure Requirement IRO-2 â Disclosure Requirements in ESRS covered by the undertakingâs sustainability statement  Sustainability Statement  List of material disclosure requirements  reference page  ESRS 2  General disclosures  Page 44  BP-1  General basis for preparation of sustainability statements  Page 45  BP-2  Disclosures in relation to specific circumstances  Page 46  GOV-1  The role of the administrative, management and supervisory bodies  Page 47  GOV-2  Information provided to and sustainability matters addressed by the  Page 48  undertaking's administrative,  management and supervisory bodies  GOV-3  Integration of sustainability-related performance in incentive schemes  Page 48  GOV-4  Statement on due diligence  Page 113  GOV-5  Risk management and internal controls over sustainability reporting  Page 49  SBM-1  Strategy, business model and value chain  Page 50  SBM-2  Interests and views of stakeholders  Page 54  SBM-3  Material impacts, risks and opportunities and their interaction with  Page 55  strategy and business model 4.  Impact, risk and opportunity management  IRO-1  Description of the processes to identify and assess material impacts, risks  Page 57  and opportunities  IRO-2  Disclosure requirements in ESRS covered by the undertaking's  Page 59  sustainability statement  Sustainability Statement  List of material disclosure requirements  reference page  E1  Climate change  E1-1  Transition plan for climate change mitigation  Page 61  ESRS 2  Integration of sustainability-related performance in incentive schemes  Page 48  GOV-3, E-1  ESRS 2  Material impacts, risks and opportunities and their interaction with  Page 64  SBM-3, E-1  strategy and business model  ESRS 2  Description of the processes to identify and assess material climate  Page 63  IRO-1, E-1  related impacts, risks and opportunities  E1-2  Policies related to climate change mitigation and adaptation  Page 66  E1-3  Actions and resources in relation to climate change policies  Page 67  E1-4  Targets related to climate change mitigation and adaptation  Page 68  E1-5  Energy consumption and mix  Page 73  E1-6  Gross Scopes 1, 2, 3 and Total GHG emissions  Page 70  E1-9  Anticipated financial effects from material physical and transition risks  Page 46  and potential climate-related opportunities  E-2  Pollution  ESRS 2  Description of the processes to identify and assess material pollution-  Page 78  IRO-1, E-2  related impacts, risks and opportunities  E2-1  Policies related to pollution  Page 78  E2-2  Actions and resources related to pollution  Page 78  E2-3  Targets related to pollution  Page 78  E2-4  Pollution of air, water and soil  Page 78  Sustainability Statement  List of material disclosure requirements  reference page  S-1  Own workforce  ESRS 2  Material impacts, risks and opportunities and their interaction with  Page 91  SBM-3, S-1  strategy and business model  S1-1  Policies related to own workforce  Page 92  S1-2  Processes for engaging with own workforce and workers' representatives  Page 93  about impacts  S1-3  Processes to remediate negative impacts and channels for own  Page 94  workforce to raise concerns  S1-4  Taking action on material impacts on own workforce, and approaches to  Page 92  managing material risks and pursuing material opportunities related to  own workforce, and effectiveness of those actions  S1-5  Targets related to managing material negative impacts, advancing  Page 93  positive impacts, and managing material risks and opportunities  S1-6  Characteristics of the undertaking's employees  Page 96  S1-9  Diversity metrics  Page 96  S1-14  Health and safety metrics  Page 97  S1-17  Incidents, complaints and severe human rights impacts  Page 99  S-2  Workers in value chain  ESRS 2  Material impacts, risks and opportunities and their interaction with  Page 100  SBM-3, S-2  strategy and business model  S2-1  Policies related to value chain workers  Page 101  S2-2  Processes for engaging with value chain workers about impacts  Page 103  S2-3  Processes to remediate negative impacts and channels for value chain  Page 103  workers to raise concerns  S2-4  Taking action on material impacts on value chain workers, and  Page 104  approaches to managing material risks and pursuing material  opportunities related to value chain workers, and effectiveness of those  actions  S2-5  Targets related to managing material negative impacts, advancing  Page 104  positive impacts, and managing material risks and opportunities  Sustainability Statement  List of material disclosure requirements  reference page  G1  Business conduct  ESRS 2  The role of the administrative, supervisory and management bodies  Page 107  GOV-1, G-1  ESRS 2  Description of the processes to identify and assess material impacts, risks  Page 105  IRO-1, G-1  and opportunities  G1-1  Corporate culture and business conduct policies and corporate culture  Page 109  G1-3  Prevention and detection of corruption and bribery  Page 110  G1-4  Confirmed incidents of corruption or bribery  Page 110  ESRS E1  Climate change  NTG's transition plan  NTG operates as an asset-light freight forwarder, specialising in customised  transport solutions across road, rail, air, and ocean. Within our international  network, we act as coordinators, planners, and negotiators, collaborating  closely with our physical transport suppliers to optimise supply chains. Most  of our carbon emissions come indirectly from our value chain. According to  the Greenhouse Gas Protocols (GHG) terminology and divisions of carbon  emissions, these are our Scope 3 carbon emissions.  E1-1  Transition plan for climate  change mitigation  NTG has committed to set our emission re-  duction targets in line with the Science Based  Targets initiative (SBTi) to limit global warming  to 1.5°C towards 2030 and reach net-zero  emissions by 2050 in line with the most recent  climate research and recommendations and  Paris Agreement goals. Already in 2023 NTG  completed calculations of relevant emissions  according to the Greenhouse Gas Protocol  from our 2022 activities that is required by  SBTi before presenting targets for reduction.  Further, we have worked on plans to reduce  emissions from various direct and indirect  sources.  NTG has in 2024 confirmed its commitment  but not yet presented our emission reduction  targets to SBTi. While we have managed to  build reduction plans for own direct emission  sources in Scope 1 and 2, it remains challeng-  ing to build trustworthy reduction targets  towards 2030 for emissions from subcontract-  ed transports that constitutes 98% of NTGâs  total emissions.  How we pursue our goals  As previously mentioned, most of our carbon  emissions are indirect, originating from  our value chain and classified as Scope 3  emissions by the SBTi and the Greenhouse  Gas Protocol. To achieve the 1.5°C target,  collaboration with our customers and support  from suppliers are essential in reducing the  carbon footprint of our supply chains. NTG  focuses on the key areas mentioned below to  reduce indirect Scope 3 carbon emissions and  promote the adoption of fossil fuel alterna-  tives in the transport sector.  Optimising customer supply chains in  collaboration with our customers  NTG, a experienced freight forwarder, actively  challenges our customersâ existing transport  setups. By analysing their current arrange-  ments, we try to identify areas for improve-  ment.  Through customised carbon emission reports  and a thorough assessment of each customersâ  setup, we strive for even greater efficien-  cy. Often, this optimisation involves minor  adjustments to transport patterns, necessitat-  ing customersâ willingness to adapt. In a next  step, we carefully evaluate the most suitable  transport mode for each shipment. By making  informed choices, we can simultaneously save  costs and reduce carbon emissions. As an  example, there is a direct correlation between  price, lead time, and emissions, and faster  transport options tend to be more costly and  emit more carbon. When feasible, based on  market conditions and timing, we explore the  possibility of âslow steamingâ by switching to  alternative transport modes.  Bio-fuels â a decarbonising alternative  NTG is committed to exploring local de-  carbonising alternatives to fossil fuels with  customers and suppliers. It is often an option  to choose decarbonising alternatives, which,  despite not yet being developed on a global  scale, can be offered locally. As an example,  bio-based fuels can already be used in various  means of transport today from trucks to  airplanes.  Battery electric vehicles  We are continuously exploring the deploy-  ment of battery electric vehicles (BEVs) on  routes that match their capacity and range  with our customers and suppliers. The ca-  pacity will still be limited and there will often  be an increased cost when choosing such  solutions compared to similar fossil-based  transport solutions.  ESRS E1  Climate-related impacts, risks  and opportunities  NTG has streamlined the Stakeholder Assessment,  enhancing our sustainability impact  E1.IRO-1  Description of the processes to identify  and assess material climate related  impacts, risks and opportunities  As part of our commitment to the ESRS  principles on double materiality and assess-  ment requirements, we have streamlined our  stakeholder assessment process.  We have based our identification of actual  and potential impacts, risks and opportunities  from information and knowledge through a  formalised dialogue with NTG's key stake-  holders.  Further, we have chosen to involve relevant  internal subject-matter experts and use them  as proxies in assessing our sustainability-relat-  ed impacts, in example our impacts on climate  change. These experts, with insights in both  business operations and Group functions, pos-  sess deep knowledge and engage in continu-  ous dialogue with our affected stakeholders.  Additionally, the group of stakeholders  provides valuable insights on sustainability  matters and assists in identifying and scoring  the impacts regarding its materiality.  Based on input from stakeholders and internal  experts, NTG has evaluated scenarios for  identifying climate-related physical and  transistional risks and opportunities in own  operations and in our value chain.  ESRS 2 â E1  KPIs  2024  Progression  Read more  Reduction of GHG Working on roadmap  NTG has committed to set our emission reduction targets  Page 69  emissions  for reaching targets  in line with SBTi to limit global warming to 1.5°C and reach  net-zero emissions by 2050. We are exploring different  technologies in close collaboration with our sub vendors.  Optimise  Made more than 200  To ensure transparency towards the customers, we have set  Page 67  customer  customised carbon  up a framework to report on customised carbon emissions  supply chains in  emission reports  to each of our customers who wants it. Based on the  collaboration with  discussions following the report, we are able to evaluate on  our customers  current set-up to reduce theirs and our carbon footprint.  Commitment to  Increased transports  In 2024, we expanded our engagement with customers  Page 67  exploring local  running on alternative  by more systematically offering bio-based fuel transports  decarbonising  fuels  as an alternative to fossil-based options. In 2025, we also  alternatives to  introduced a fully electric operated truck among our own  fossil fuels  fleet.  Own  IRO  Upstream  operation Downstream  1Emissions from value chain operations  Actual negative impact  â2Energy consumption in own operations  Actual negative impact  â3Low carbon transports and services  Opportunity  âESRS 2 SBM-3, E-1  Material impacts, risks and opportunities  NTG has identified two impacts and one opportunity  to be material in relation to climate change:  â¶Emissions from value chain operations  Impact  NTG arranges low to medium-carbon emitting  transport operations performed by suppliers  on behalf of customers and for this reason,  NTG depends on fossil fuels to run its busi-  ness. The use of fossil fuels contributes to  the release of GHG emissions, which impacts  global warming negatively.  The GHG emissions are emitted mainly in  the downstream value chain when suppliers  conduct transports on behalf of NTG.  The consequences of climate change attract  more attention in society in general and our  various stakeholder groups raise concerns on  how NTG can minimise the impact of climate  change more frequently.  â·Energy consumption in own operations  Impact  While the majority of NTGâs emissions orig-  inate from our value chain, we also manage  few assets directly, including buildings, com-  pany cars, and a small fleet of trucks.  These assets contribute to carbon emissions  through their energy and fuel consumption  during operations. NTGâs own assets consume  energy resources to perform its services,  which releases GHG emissions and constitutes  a negative impact on the climate.  â¸Demand for zero/low carbon transports  Opportunity  Climate change and a transition to carbon  neutrality may lead to shifts in customer  needs and demands, which may lead to a  demand for zero/low carbon transports.  NTG could potentially fulfil these demands  by taking the lead on the transition towards  a more sustainable supply chain.  Low carbon fuels and technologies come with  a premium, and if customers are willing to pay  this extra cost for "green" solutions, it could  imply raising revenues for NTG.  The opportunity is already incorporated in  NTG's general strategy and in our dialogue  with our customers on possible options to  reduce emissions from our offered transport  and logistic services.  E-1.SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Resilience analysis of NTG's strategy  and business model  NTG has confirmed its commitment to set our emission reduc-  tion targets in line with the SBTi to limit global warming to 1.5°C  towards 2030 and reach net-zero emissions by 2050 in line with  most recent climate research and recommendations and Paris  Agreement goals.  In 2025, we intend to further improve our work on mapping our  activities within different emission categories in detail, to get a  solid baseline and understanding of the reduction targets that  must be prepared to build up a baseline for our future improve-  ments.  This also includes creating a resilient plan for reducing carbon  emissions from various direct and indirect sources categorised  as Scope 1, 2 and 3. This is the backbone of NTGâs climate resil-  ience analysis of our strategy and business model.  Limited alternatives for our industry  The transport sector still has few viable alternatives to fossil  fuels as an energy source. We rely on continuous technologi-  cal innovation, and the pace of development in the industry is  crucial.  These alternatives face significant challenges in terms of  scalability, technology, and infrastructure at local, regional,  and global levels. Additionally, the higher costs associated with  these alternatives act as a barrier, as only a few stakeholders are  willing to share these expenses, further hindering widespread  adoption.  ESRS E1  Policies related to climate change  mitigation and adaptation  NTG's environmental and climate policies address both climate change mitigation and  climate change adaptation. Following is a short description the key contents of our policies.  E1-2  Code of Conduct for Employees  Environment  We recognise our responsibility to minimise our environmental  impact and support eco-friendly initiatives to address climate  change mitigation such as renewable energy deployment. We  comply with environmental regulations and aim to adopt new  technologies for positive environmental effects.  To adapt to climate change, we are certifying NTG companies  with ISO 14001 and encourage employees to engage in pollu-  tion reduction, resource conservation, and other environmental  protection activities.  Code of Conduct for Suppliers  Environment and climate  As an asset-light freight forwarder, NTG's climate impact mainly  comes from indirect emissions through suppliers. Collaboration  with customers and suppliers is crucial for reducing carbon  emissions. Suppliers must comply with environmental laws and  support NTG's carbon reduction initiatives, participating in joint  eco-friendly projects. To adapt to climate change, NTG expects  suppliers to minimise vehicle idling and keep drivers informed  on efficient driving techniques to ensure low fuel consumption.  ESG and Diversity Policy  Environmental impact  Finally, as stated in our ESG and Diversity Policy and the section  on environmental impact, it is NTGâs aim to provide higher  transparency on our level of carbon emissions and further that  NTG performs annual estimations of our carbon emissions in  accordance with the Greenhouse Gas Protocol principles and  industry-based best practices. Initiatives to increase NTGâs  carbon efficiency and decrease our total carbon footprint are  continuously analysed and evaluated.  Bringing transparency to the area of carbon emissions is  important to create actionable insights which enable continued  improvements and promote sustainable service offerings to our  customers.  Further, we mention that NTGâs direct emissions mainly relate to  office buildings and terminals where we are in a better position  to control the environmental impact. Albeit direct emissions are  very limited, we continuously strive to identify viable opportu-  nities to reduce direct emissions through energy efficiency and  savings across locations.  ESRS E1  Actions and resources in relation  to climate change policies  E1-3  Streamlining customer supply chains  NTG produces several customer-specific reports annually to  calculate carbon emissions from the transport activities they have  purchased. These reports are highly valued by our customers.  While some use them for their own carbon emission invento-  ries, many find them instrumental in identifying ways to reduce  their environmental impact from transport. The reports bring  the customers transparency in their supply chain on the highest  emitters of emissions and thereby highlighting where reduction  efforts can be applied most effectively. Additionally, these reports  provide a baseline for setting reduction targets and monitoring  progress over time, which customers have found essential for  their sustainability initiatives. Any GHG emission reduction from  these activities have not been quantified.  Bio-fuel â a decarbonising alternative  NTG is committed to exploring local decarbonising alternatives  to fossil fuels. In 2024, we expanded our engagement with  customers by more systematically offering bio-based fuel trans-  ports as an alternative to fossil-based options.  NTGâs Swedish domestic road company, has since 2023 used  Hydrotreated Vegetable Oil (HVO), a bio-based fuel. Although  HVO is more expensive than standard bio-blended diesel, its  introduction was phased into the transports gradually in 2023.  Our key customers agreed to an increased diesel surcharge in  exchange for a significant reduction in emissions from their  transport services. Following this success, the company began  discussions with its subcontractors to start using HVO and to  agree on compensation for the increased costs.  In 2024, NTGâs subcontractors fuelled over a million litres of  HVO100 fuel, saving more than 2.7 million tonnes of CO2e  emissions compared to the emissions that would have been  produced using European standard bio-blended diesel.  Battery electric vehicles  We are continuously exploring the deployment of battery  electric vehicles (BEVs) on routes that match their capacity and  range.  Just like our approach to the bio-based fuel, HVO, this process  also follows a step-by-step process. We began by initiating a di-  alogue with individual customers, followed by discussions with  one or more subcontractors. Since purchasing a BEV can be up  to three times more expensive than a fossil-fuelled truck, it is  crucial for NTG to secure the investment in collaboration with  both the customer and the subcontractor.  Additionally, it is essential for all parties to agree on any neces-  sary investments in charging facilities for the BEVs, as the public  network of charging stations for BEVâs is not as developed as  those for electric cars in Northern Europe. Late in 2024, we  introduced a fully electric operated truck among our own fleet  and in the beginning of 2025, one of our Danish-based road  subcontractors finally received a delayed, but long-awaited,  truck dedicated to service a customerâs linehaul between pro-  duction and warehouse facilities. Any GHG emission reduction  from thise activity has not been quantified.  The last two examples of actions aimed at mitigating our climate  change impact could potentially reduce NTGâs direct scope 1 or  our indirect scope 3 GHG emissions, depending on whether the  asset is owned by NTG or a supplier  ESRS E1  Targets related  to climate change  mitigation and  adaptation  E1-4  In line with our commitment to managing material climate  change impacts, NTG is setting concrete targets to mitigate  our environmental footprint. We aim to establish two global  targets to reduce our GHG emissions. The first target will be an  absolute reduction of our combined Scope 1 and Scope 2 GHG  emissions from our own activities. The second target will likely  be an intensity reduction for emissions from our value chain,  addressing Scope 3 GHG emissions from both upstream and  downstream activities.  In 2024, NTG confirmed its commitment but has not yet  presented our emission reduction targets to the SBTi. This  impluthat NTG has not yet set targets to manage our materiel  climate-related impacts. We have developed reduction plans  for our direct emission sources in Scope 1 and 2 but creating  reliable reduction targets for subcontracted transports towards  2030, which constitute approximately 98% of NTGâs total emis-  sions, remains a challenge.  We have identified two key strategies to achieve our targets.  To reduce Scope 1 and 2 GHG emissions, we must transition to  renewable energy across our own operations. To reduce Scope  3 GHG emissions, we need to collaborate with customers and  suppliers to lower emissions from our transport activities.  ESRS E1  Gross Scopes 1, 2, 3 and Total GHG emissions  Our own activities contribute to carbon emissions in various ways, such as energy  use in our buildings and fuel consumption in our own vehicles. These emissions are  classified as Scope 1 and Scope 2 according to the Greenhouse Gas Protocol.  E1-6  Scope 1 GHG emissions â general overview  Our own activities contribute to carbon emissions in various  ways, such as energy use in our buildings and fuel consumption  in our vehicles. These emissions are classified as Scope 1 and  Scope 2 according to the Greenhouse Gas Protocol.  The increased number of assets, which was a result of NTGâs  acquisitions in 2024, inevitably resulted in an increase of the  direct emissions from owned and controlled assets - the Scope  1 and Scope 2 emissions.  The higher consumption from owned and controlled assets con-  stitutes a 39% increase in Gross Scope 1 GHG emissions (TTW  approach) in 2024.  Since 2022, NTGâs policy on company cars has been in force,  which allows only electric or plug-in hybrid electric vehicles  (PHEV). Despite the latest acquisitions bringing a number of  fossil fuelled company cars into the totals, the share of electric  and PHEV still grew slightly compared to last year.  Scope 2 GHG emissions â general overview  The indirect emissions from the generation of electricity, heat,  or steam that we purchase have increased by approximately  19% in 2024. This is a result of an increasing electricity and  district heating consumption in our buildings, combined with an  increased demand for charging our growing fleet of company  cars by electricity.  Renewable energy production through our own  roof-top solar panels  The roof-top mounted solar installations in some of the NTG  entities continue to produce more electricity with zero carbon  footprint. During the reporting period, NTG more than doubled  its installed capacity. The power produced is used directly by  the NTG entities and it reduces the amount of electricity they  purchase and consume from the grid, and consequently, lowers  their Scope 2 GHG emissions. Compared to previous year, in  2024, the production of renewable energy by the roof-top solar  panels has increased by more than 33%, and along with this, the  consumption of the self-produced renewable energy increased  by 39%.  The Scope 2 emissions saved by the self-generated renewable  energy equals 121 tons CO2 (location-based)  The table on next page illustrates the allocation of Scope 1 and  2 GHG emissions by country, with an emphasis on the first three  countries with highest amounts of emissions from own activities  â Germany, Denmark and Sweden. The highest emissions in  these countries are a natural consequence of the significant  concentration of activities and large asset base of the NTG  entities operating in these countries.  Scope 3 GHG emissions - overview  The largest part of our carbon emissions (%) come indirectly  from our value chain. According to the Greenhouse Gas Proto-  cols terminology and divisions of carbon emissions, these are  our Scope 3 carbon emissions.  Even though the decarbonising solutions come with increased  costs compared to traditional fossil-based transport options, the  initiative is well received by customers and subcontractors. In  2024, more than 1,332,000 litres of HVO fuel have been fuelled  (three times more than previous year) saving more than 2,600  tons of Scope 3 CO2e emissions compared to the emissions if  European standard bio-blended diesel had been used. The saved  emissions in 2024 are more than 3 times more than those saved  during the previous year in relation to the consumed HVO fuel  (2,604 tons CO2e in 2024 compared to 691 tons CO2e in 2023).  ESRS ID  Unit  2024  2023*  1. Gross scopes 1, 2, 3 and total GHG emissions  E1-6_01, E1-  Gross Scope 1 GHG emissions and total GHG emissions  6_02, E1-6 -04,  (Tank-to-wheel)  7,765  7,254  E1-6-05, E1-  Buildings  tonnes CO2e  1,217  731  6_06, E1-6-07,  Company cars  tonnes CO2e  1,188  1,060  E1-6-11  Own/leased trucks and forklifts  tonnes CO2e  5,360  5,463  Gross Scope 2 GHG emissions and total GHG emissions  (Location-based) (Tank-to-wheel)  1,451  1,225  Buildings  tonnes CO2e  1,389  1,225  Company cars  tonnes CO2e  60  N/A  Electric trucks  tonnes CO2e  2N/A  Gross Scope 3 GHG emissions (Tank-to-wheel)  580,323  596,755  Road transport  tonnes CO2e  338,621  380,322  Railway transport  tonnes CO2e  205  8Air transport  tonnes CO2e  141,465  114,820  Ocean transport  tonnes CO2e  100,032  101,604  Total GHG emissions (Tank-to-wheel)  Total CO2e GHG emissions - scope 1, 2 and 3  tonnes CO2e  589,539  605,233  * The comparative information for 2023 is not covered by PwC's CSRD limited assurance on page 170.  ESRS ID  Biogenic emissions  Unit  2024  2. GHG emissions outside of scopes  E1-6_28  Biogenic emissions of CO2 from combustion or bio-degradation of  tonnes CO2e  2,722  biomass that occur in value chain not included in Scope 3 GHG emissions  3. GHG emissions intensity  E1-6_30  GHG Emission intensity â Location-based -  tonne CO2/  0.83  Scope 1 emissions (Tank-to-wheel)  DKKm  GHG Emission intensity â Location-based -  tonne CO2/  0.16  Scope 2 emissions (Tank-to-wheel)  DKKm  Total GHG Emission intensity â Scope 1 and 2 emissions (Tank-to-wheel)  tonne CO2/  0.99  DKKm  Total  Scope 1  Scope 1  (TTW)  ESRS ID  Country  Unit  (TTW)  Scope 2  +Scope 2  4. Scope 1 and Scope 2 GHG emissions  â split by country:  Countries with highest emissions  E1-6_03  Germany  tonnes CO2e  3,305  357  3,662  Denmark  tonnes CO2e  2,276  265  2,541  Sweden  tonnes CO2e  1,006  125  1,131  Other  tonnes CO2e  1,178  704  1,882  Total  tonnes CO2e  7,765  1,451  9,216  Accounting policies, methodologies and significant assumptions  Accounting policy  Key accounting estimations and assumptions, Scope 1, 2  and 3 GHG emissions  There are inherent sources of estimation and uncertainty  in GHG emissions. These uncertainties stem from the  methodologies and assumptions employed in calculations.  To minimise these uncertainties and maintain transparen-  cy, NTG follows established standards and protocols.  Scope 1 and 2 GHG emissions are calculated using actual  data where available, combined with emission factors for  relevant activities. Estimates have been applied when ac-  tual data on consumption was not available. Estimates have  been based on factors applied from similar activities in  NTG in accordance with internal NTG reporting guidelines.  Scope 3 GHG emissions are calculated using actual trans-  port data from own transport management systems where  available covering 97% of our transport activities. The  remaining emissions are estimated based on extrapolation  of information on revenue from transport activities to  reach full coverage of our transport activities.  E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions  NTG's carbon footprint provides a general overview of the  company's greenhouse gas emissions converted into CO2  equivalents (CO2e). The emissions reported in scope 1, 2  and 3 are inspired by the definitions in the GHG Protocol.  The reported total scope 1, 2 and 3 emissions consolidate  the emissions data of all companies in the structure of  NTG, all of them being under the full financial and opera-  tional control of NTG, and each one of them being a part  of the consolidated accounting group. NTG doesn't have  in its structure any other entities, activities or projects  for which it has operational control (i.e. "investees such as  associates, joint ventures, or unconsolidated subsidiaries  that are not fully consolidated in the financial statements  of the consolidated accounting group, as well as contractu-  al arrangements that are joint arrangements not structured  through an entity").  Gross scope 1 GHG emissions (E1-6_07)  Direct carbon dioxide equivalent (CO2e) emissions based  on reported or estimated consumption from owned or  controlled sources, which are company cars and forklifts  powered by fossil fuels, our own small fleet of trucks,  forklifts used in our terminals and warehouses (fuelled  with diesel or propane gas) and consumption of natural gas  or heating oil in own buildings. Emissions from buildings  are calculated using emission factors from UK Government  GHG Conversion Factors for Company Reporting, Version  1, 2024 (DEFRA). Emissions from company cars, forklifts  and owned trucks are calculated using emission factors  per relevant fuel type from DEFRA and the GLEC Frame-  work for logistics emissions, accounting and reporting,  version 3.1 (GLEC). Scope 1 GHG emissions are disclosed  using the Tank-to-wheel (TTW) approach.  Gross location-based Scope 2 GHG emissions (E1-6_09)  Scope 2 GHG emissions are calculated and disclosed  by applying the location-based approach following the  GHG protocol. The basis for calculating the Scope 2 GHG  emissions is NTG entities' reported or estimated (in some  specific cases) consumption from purchased electricity and  district heating in own buildings; and from purchased and  consumed electricity in own company cars and one electric  truck. The frameworks used as a sourse basis of emission  factors for calculating CO2 emissions are www.ourworldin-  data.org for the electricity emission factors for the energy  used both in buildings and vehicles, and DEFRA regarding  dictrict heating consumption in own buildings.  Disclosure of significant changes in definition of what  constitutes reporting undertaking and its value chain and  explanation of their effect on year-to-year comparability  of reported GHG emissions (E1-6_14)  No significant changes on group level that would impact  the overall year-to-year comparability of reported GHG  emissions.  Gross Scope 3 greenhouse gas emissions (E1-6_11), Gross  Scopes 1, 2, 3 and Total GHG emissions â Scope 3 GHG  emissions (GHG Protocol) (E1-6_04), Gross Scopes 1, 2, 3  and Total GHG emissions â Scope 3 GHG emissions (ISO  14064-1) (E1-6_05), Gross Scopes 1, 2, 3 and Total GHG  emissions â total GHG emissions â value chain (table  E1-6_06), Percentage of GHG Scope 3 calculated using  primary data (E1-6_25), Disclosure of why Scope 3 GHG  emissions category has been excluded (E1-6_26), List of  Scope 3 GHG emissions categories included in inventory  (E1-6_27), Disclosure of reporting boundaries considered  and calculation methods for estimating Scope 3 GHG  emissions (E1-6_29)  NTG is reporting on the GHG Protocol's Scope 3, category 4  (Upstream transportation and distribution) as transportation  and distribution services is our core business and the main  part of the services/capacities are purchased from hauliers,  ocean carriers, airlines, and other capacity providers and  more than 98% of the total carbon emissions originates  from our subcontracted activities. NTG's GHG emissions  from remaining GHG Scope 3 categories are category 1, 2, 3,  5, 6 and 7. These categories were assessed in 2022 and the  total emissions from these categories was approx. 3.5% of  NTG's total GHG emissions. NTG are working on dislcosing  data from relevant categories in 2025. NTG Group's revenue  generating activities are the basis for data for calculating  the Scope 3, category 4 emissions eliminated for irrelevant,  non-transport revenue generating activities.  Indirect CO2 emissions from transport activities are aligned  with methodolgies in the GLEC Framework. Carbon dioxide  equivalent emissions are disclosed following the Tank-To-  Wheel (TTW) approach for our transport activities except  where otherwise stated. Scope 3, category 4 emissions  are calculated based on transport data from NTG standard  transport management systems (93%) and from legacy  transport management systems (7%), including data on  freight volumes transported by different transport modes  to and from different destinations. As data from our stand-  ard transport management systems is considered to contain  greater transparency, and NTG plans to transfer activities  from legacy transport management systems to standard  transport management systems.  Transport data from our standard and legacy transport  management systems cover 97% of scope 3 GHG emissions  from our transport activities. The remaining emissions are  estimated based on extrapolation of information on reve-  nue from transport activities and average emission factors  to reach full coverage of emission from our activities.  For road transports NTG estimate emissions partly on the  average fuel utilisation ratios reported for trucks owned by  NTG and by subcontractors and used for the transports of  Accounting policies, methodologies and significant assumptions  Accounting policy  NTG's customers freight, and partly on transport data from  NTG's traffic management systems.  For railway transports NTG estimates emissions partly  on the average emissions from the EcoTransIT World  calculator using data from main fossil fuelled traffic lines  for the transports of NTG's customers freight, and partly on  transport data from NTG's traffic mangament systems. The  data base for railway carbon emission calculations is subject  to uncertainty and is not complete. Incomplete data for  railway transport is included conservatively among NTG's  other modes of transport. We will continue our work on  improving the insufficient data base.  For ocean transports NTG estimates emissions partly on the  Clean Cargo Working Group, which collects information on  global container shipping trade lane emissions factors from  subcontractors used by NTG for the transports of NTG's  customers freight, emission factors from GLEC and partly  on transport data from NTG's traffic management systems.  For air transports NTG estimates emissions partly on the av-  erage carbon emissions reported by subcontractors and used  for the transports of NTG's customers freight, and partly on  transport data from NTG's traffic management systems.  GHG emissions â by country, operating segments,  economic activity, subsidiary, GHG category  or source type (E1-6_03)  The table presents the distribution of Scope 1 and 2 GHG  emissions by country, showing the three countries with  highest emissions.  Biogenic emissions of CO2 from combustion  or bio-degradation of biomass that occur in value chain  not included in Scope 3 GHG emissions (E1-6_28)  The metric presents Scope 3 biogenic emission from  combustion of biofuel (HVO 100) calculated as a TTW  emission. This biogenic emission is considered out of the  other emission scopes and is calculated based on the  consumption of HVO100 fuel purchased by subcontractors  and used to perform transports by NTG entities. Source of  the emission factor is GLEC.  GHG emissions intensity, location-based  (total GHG emissions per net revenue) (E1-6_30)  Total GHG emissions (scope 1, 2 and 3) divided by unit  of total net revenue. Scope 1 GHG emissions intensity is  presented as intensity of emissions calculated by TTW ap-  proach â this applies to the summed-up amounts of Scope  1 and 2 emissions as well. For calculating the emissions  intensity, Scope 2 emissions are presented following the  location based approach.  Biogenic emissions of CO2 from combustion or bio-degra-  dation of biomass not included in Scope 1 GHG emissions  (E1-6_24)  No Scope 2 related biogenic emissions of CO2 from the  combustion or bio-degradation of biomass.  Biogenic emissions of CO2 from combustion or bio-degra-  dation of biomass not included in Scope 2 GHG emissions  (E1-6_24)  No Scope 2 related biogenic emissions of CO2 from the  combustion or bio-degradation of biomass.  Net revenue other than used to calculate  GHG intensity (E1-6_35)  NTG has no revenue from any other activities.  Percentage of Scope 1 GHG emissions from regulated  emission trading schemes (E1-6_08)  NTG doesn't participate in regulated emission trading  schemes.  Disclosure of reconciliation to financial statements  of net revenue used for calculation of GHG emissions  intensity (E1-6_32)  The net revenue has been reconciled to the Annual Report,  page 20, Condensed Income statement.  Net revenue (E1-6_33),  Net revenue used to calculate GHG intensity (E1-6_34)  The net revenue has been reconciled to the Annual Report,  page 20, Condensed Income statement.  ESRS E1  Targets related to climate change  mitigation and adaptation  E1-5  Energy consumption and mix  The energy consumption and mix in NTGâs own operations  and controlled entities is presented in the tables on this page.  During 2024, NTGâs energy consumption relates to NTGâs own  operations, representing energy from fossil sources (oil and  petroleum products and natural gas) from fuels, electricity,  and district heating.  Renewable sources include energy produced and consumed  from roof-top mounted solar panels in NTGâs buildings.  ESRS ID  Metric  Unit  2024  1. Energy consumption  E1-5_01,  Total energy consumption  MWh  150,055  E1-5_19  E1-5_02  Energy consumption from fossil sources  MWh  31,532  E1-5_11  Fuel consumption from crude oil  MWh  25,933  and petroleum products  E1-5_12  Fuel consumption from natural gas  MWh  5,600  E1-5_14  Consumption of purchased or acquired electricity,  MWh  118,522  heat, steam, or cooling from fossil sources  2. Renewable energy:  production and consumption  E1-5_05  Total energy consumption from renewable sources  MWh  635.58  E1-5_08  Consumption of self-generated  MWh  635.58  non-fuel renewable energy  3. Energy intensity and mix  E1-5_18  Energy intensity per net revenue  MWh/  16.05  DKKm  E1-5_09  Percentage of renewable sources in  %0.42  total energy consumption  E1-5_15  Percentage of fossil sources in total energy consumption  %99.58  Accounting policies, methodologies and significant assumptions  Accounting policy  All reported energy metrics refer to NTG's own operations  and controlled entities, assets and vehicles. All metrics de-  rives from information collected from all NTG entities per  asset type and relevant consumption based on presented  consumption documentation. To ensure completeness in  the reported data, estimations were used in some specific  cases where the data from actual consumption was inac-  cessible. Estimations are based on the average consump-  tion for the respective asset and type of consumption from  other NTG entities.  Any measurements of metrics related to energy consump-  tions disclosed have not been validated other than by the  assurance provider.  Total energy consumption (E1-5_01) and  Total energy consumption from activities  in high climate impact sectors (E1-5_19)  The reported amount of total energy consumption includes  the energy consumption from fossil sources (crude oil and  petroleum products, and natural gas fuels) and the Con-  sumption of purchased or acquired electricity, heat, steam,  or cooling from fossil sources.  The same amount has been reported under datapoint  E1-5_19 (Total energy consumption from activities in high  climate impact sectors) due to the assumption that all all  NTG activities are in high climate impact sector â all own  activities of the company are supporting transportation.  Transportation activities fall within NACE code, section  H â Transporting and storage as defined in the Regulation  (EU) 2019/2088 and Annex 1 of the related Delegated  Regulation with regard to disclosure rules on sustainable  investments.  Energy consumption from fossil sources (E1-5_02)  The reported amount of energy consumption from fossil  sources includes the crude oil and petroleum products,  and natural gas fuels. This numbers includes in itself the  amounts reported in the two rows below under datapoints:  Fuel consumption from crude oil and  petroleum products (E1-5_11)  Includes the consumption of burning oil used for heating  of owned and leased building premises; and the fossil fuels  used for owned and leased cars and trucks â gasoline (cars)  and diesel (cars, trucks, forklifts fueled by diesel).  Fuel consumption from natural gas (E1-5_12)  Includes natural gas used for heating of owned and leased  building premises and the gas propane used for fueling of  owned and leased forklifts.  Fuel consumption from other fossil sources (E1-5_13)  NTG doesn't consume fuel from other fossil sources than  already disclosed. No fuel consumption from coal and  coal products (datapoint E1-5_10).  Fuel consumption from  coal and coal products (E1-5_10)  NTG doesn't have any fuel consumption from coal  and coal products.  Consumption of purchased or acquired electricity, heat,  steam, or cooling from fossil sources (datapoint E1-5_14)  Includes the total electricity consumption from owned and  leased buildings, cars, and electric trucks, and the district  heating for buildings. Further, these components of the  consumption are used as the basis for calculating of Scope 2  GHG emissions.  The reported number includes in itself the consumption of  self-generated renewable energy from NTG entities with  roof-top mounted solar panels.  Total energy consumption from nuclear sources (E1-5_03)  NTG does not have available information which could  distinguish any direct energy consumption from nuclear  sources.  Percentage of energy consumption from nuclear  sources in total energy consumption (E1-5_04)  NTG does not have available information which could  distinguish any direct energy consumption from nuclear  sources.  Total energy consumption  from renewable sources (E1-5_05)  Only the self-generated renewable energy produced from  own solar panels can be distinguished (it is reported in  datapoint E1-5_08, see below). NTG doesn't have any  available information about direct energy consumption  from renewable sources regarding energy purchased from  specific suppliers.  Fuel consumption from renewable sources (E1-5_06)  Only the self-generated renewable energy produced  from own solar panels can be distinguished (it is reported  in datapoint E1-5_08, see below). NTG don't have any  available information about direct energy consumption  from renewable sources regarding energy purchased from  specific suppliers.  Consumption of purchased or acquired electricity, heat,  steam, and cooling from renewable sources (E1-5_07)  No specific information about the electricity purchased  dirctly from suppliers of energy from renewable sources.  NTG doesn't consume any directly purchased heat, steam  or cooling from renewable sources.  Energy intensity from activities in high  climate impact sectors â total energy consumption  per net revenue (E1-5_18)  The metric is calculated as a total energy consumption  in high climate impacts sectors per unit of net revenue  (DKKm), so the result is presented as MWh/DKKm.  High climate impact sectors used  to determine energy intensity (E1-5_20)  All NTG energy consumption is considered related to high  climate impact sector because all own activities of the  company are supporting transportation. Transportation ac-  tivities fall within NACE code, section H â Transporting and  storage as defined in the Regulation (EU) 2019/2088 and  Annex 1 of the related Delegated Regulation with regard to  disclosure rules on sustainable investments.  Accounting policies, methodologies and significant assumptions  Accounting policy  Net revenue from activities  in high climate impact sectors (E1-5_22)  As NTG has zero revenue from activities other than in high  climate impact sector â transportation, the net revenue  is used for the metric as it is disclosed in NTG's Annual  Report, page 9, line 1 (Five-year financial overview).  Percentage of renewable sources  in total energy consumption (E1-5_09)  The metric presents the consumed self-generated renew-  able energy produced by NTG entities roof-top mounted  solar panels, reported in datapoints E1-5_05 and E1-5_08),  as a share of the total energy consumption (reported in  datapoint E1-5_01). The assumption is that the produced  renewable energy from the own solar panels of the in-  dicated 3 NTG entities was directly consumed by them  and the surplus was sold to the grid.  Percentage of fossil sources  in total energy consumption (E1-5_15)  The metric is based on the assumption that all NTG's  energy consumption from own activities comes from  from fossil sources except the energy produced from  the own solar panels as indicated above. Therefore, the  metric reflects the 100 % fossil sources, out of which  has been deducted the percentage of consumption of  self-generated renewable energy.  Total energy consumption  from renewable sources (E1-5_05)  Only the self-generated renewable energy produced from  own solar panels can be distinguished (it is reported in  datapoint E1-5_08, see below). NTG doesn't have any  available information about direct energy consumption  from renewable sources regarding energy purchased from  specific suppliers.  Consumption of self-generated non-fuel  renewable energy (datapoint E1-5_08)  The assumption is that the produced renewable energy  from the NTG enitities own roof-top mounted solar panels  was directly consumed by them and the surplus produced  energy was sold to the grid. Therefore both datapoints  E1-5_05 and E1-5_08 are reported through the same  metric, as based on the available data, the consumption of  self-generated renewable energy is the only clearly distin-  guishable source from the full range of renewable sources  in the electriciy mix. The consumption number presented  in both datapoints has been calculated by deducting the  produced energy sold to the grid from the total produced  renewable energy by the own roof-top mounted solar  panels of the relevant NTG entities.  E1-7  GHG removals and GHG mitigation  projects financed through carbon credits  NTG has not financed any GHG removals or GHG mitigation  projects through carbon credits.  E1-8  Internal carbon pricing  NTG does not apply internal carbon pricing schemes in its  business.  ESRS E2  Pollution  NTG's transport activities are conducted through  our network, which includes transport solutions  by road, rail, air, and ocean that we engage on  behalf of our customers.  All these different means of transport are powered by the com-  bustion of fossil fuels, which is a major driver of air pollution.  NTG has assessed that this has a material pollution-related  impact in our upstream value chain.  NTG has used the same approach as described in IRO-1 on page  57 to identify and assess material impacts, risks, and opportuni-  ties in relation to actual and potential pollution-related impacts  from NTG's activities in own operations as well as in upstream  and downstream value chain activities.  ESRS 2  NTG's impacts,  risks and  opportunities  NTG efforts to reduce GHG  emissions will have a dual benefit  for air quality and climate  IRO-1, E-2  Description of the processes to identify  and assess material pollution-related  impacts, risks and opportunities  When fossil fuel is burned in a means of  transport to generate energy for propulsion, it  results in the release of a variety of pollutants  into the atmosphere. These include particulate  matter, sulphur dioxide (SOâ), nitrogen oxides  (NOâ), and volatile organic compounds (VOCs).  The same combustion process also releases  significant amounts of carbon dioxide (COâ),  methane (CHâ), and nitrous oxide (NâO), which  are potent greenhouse gases.  The World Health Organisation (WHO) states  that: "Air quality is closely linked to the earthâs  climate and ecosystems globally. Many of  the drivers of air pollution (i.e. combustion of  fossil fuels) are also sources of greenhouse  gas emissions. Policies to reduce air pollution,  therefore, offer a win-win strategy for both  climate and health, lowering the burden of  disease attributable to air pollution, as well  as contributing to the near- and long-term  mitigation of climate change".  NTG concludes from WHO's approach that re-  ducing transport-related emissions in general  not only benefits the immediate environment  but also has a ripple effect throughout the  upstream value chain, leading to broader  reductions in air pollution. There is a direct  correlation between NTG's efforts to reduce  GHG emissions from our activities that will  also result in a one-to-one reduction of air  pollutants.  The customersâ focus is only on GHG  emissions  NTG has an ongoing dialogue with its custom-  ers on the environmental impact of our trans-  ports. NTG creates several customer specific  reports yearly with the purpose of calculating  carbon emission from the purchased transport  activities of NTG.  These customer requests concern GHG emis-  sion data, but never any data on air pollut-  ants. This is likely because NTG's customers  typically are located in nations and regions  where, for decades, they have been successful  in regulating and limiting pollution from the  discharge of various fossil fuel sources. With  the increasing awareness of our customers  about the climate crisis and rising global  temperatures, the focus is now exclusively  on limiting the emission of climate changing  greenhouse gases.  As a service company, we must comply with  our customers' requirements for a focus on  reducing GHG emissions from our transport  activities. Furthermore, when there is a direct  connection between greenhouse gases and  pollution from the burning of fossil fuels, it is  sensible for NTG to focus on reducing GHG  emissions.  E2-1, E2-2, E2-3, E2-4  NTG's position on the impact on air  pollution  Material impacts, risks, and opportunities  regarding air pollution are a part of the envi-  ronmental protection topic, and therefore an  important part to consider in NTGâs impact  on the environment and climate through our  business activities.  NTG acknowledge in its Code of Conduct  for Employees that the approach to minimise  these negative impacts and air pollution is a  material part of its impact.  The disclosure requirements defined in ESRS  for air pollution focus on own operations and  facilities where operational or financial control  is a parameter. However, NTG does not have  direct control over these aspects, as the  impact originates from the value chain. This  is why NTG does not include specific metrics,  actions or targets on air pollution but intend  to continue to work on reduction of GHG  emissions as described in section E1, Climate  change. These measures are all aimed at de-  creasing fuel consumption and, consequently,  the number of pollutants released into the  atmosphere from our upstream supply chain  activities.  NTG will continue our close collaboration with  our customers and suppliers to minimise the  transport-related GHG emissions from our  value chain. Going forward, NTG will commu-  nicate the correlation between GHG emis-  sions and air pollution to customers to address  and highlight the impact on air pollution from  our value chain.  Own  IRO  Upstream  operation Downstream  â4Air pollutants  Actual negative Impact  ESRS S1  Own workforce  NTG operates on a global scale through a decentralised  organisational structure and locally anchored expertise in multiple  countries, enabling us to manage shipments of any size, destination,  or complexity. Our advanced technology platforms provide  efficient, reliable, and cost-effective logistics solutions tailored to  our customersâ specific needs and preferences.  Nevertheless, technology alone is insufficient  to achieve our objectives. We also depend  on passionate and dedicated employees who  embody and comprehend NTGâs vision and  values. Our employees engage with customers  and suppliers daily, executing strategies and  plans while understanding the impact of their  work on our customers, the company, and the  communities in which we operate.  NTGâs employees consistently strive for excel-  lence and endeavour to create positive out-  comes for all stakeholders. As a service-ori-  ented company, NTG relies on the skills and  qualifications of its employees to attain its  goals. Each employee plays a vital role in  fulfilling the NTG Groupâs vision of being the  preferred choice for transport solutions.  NTG directly influences its employees through  its established company culture, benefits,  policies, and practices  ESRS 2 â S1  KPIs  2024  Progression  Read more  Reduce rate of recordable  4.5  Despite our efforts, we do record incidents each year where  Page 98  work-related accidents for  employees sustain injuries. To mitigate these occurrences,  own workforce, per  we document and analyse every incident to determine the  million working hours  cause.  every year  We will have no fatalities  0 fatalities  NTG has been measuring, monitoring, and reviewing our  Page 98  among our employees  health and safety protocols and acted on any escalations.  This have meant another year without any fatalities. We aim  to keep it that way.  Top management targets  9.1%  Top management (Executive Management team and their  Page 97  to reach a representation  direct reports with managerial responsibilities) consisted of  of 10% of the  11 employees with a gender distribution of 90.9% males and  underrepresented  9.1% female  gender in 2027 at the  latest.  Own  IRO  Upstream  operation Downstream  5Health and safety  Actual negative Impact  â6Diversity  Risk  â7Privacy  Actual negative Impact  âSBM-3  Material impacts, risks and opportunities  and their interaction with strategy and  business model  NTG has identified two negative impacts and a risk that are being  assessed as material to NTG within the topic own workforce.  â¶Health and Safety, negative impact  NTG has identified health and safety as a  material impact, particularly for warehouse  employees and own-employed truck drivers.  These groups face risks of injuries and other  health issues in the workplace, which could  negatively affect their lives, potentially caus-  ing fatalities.  â·Privacy, negative impact  NTG is a company that operates in the trans-  port and logistics industry, where each day  vast volumes of data are generated. This is  why all NTG employees are subject to privacy  impacts due to data collection from various  sources, such as transport management  systems, salary administration, employment  registration, and video surveillance.  There are various regulations in place to  protect this data, and NTG must protect this  data from unauthorised access or misuse,  respecting the privacy and rights of individ-  uals. Obtaining some of this data is crucial  for NTG's operations, including customer  arrangements and transport supervision,  and is collected from employees, applicants,  visitors, customers, business partners, and  third parties.  â¸Diversity, risk  NTG recognises the importance of gender  diversity and the associated material risks. As a  Danish-based publicly listed company, there is  increasing focus on gender diversity, particular-  ly in meeting authority requirements for gender  composition among the Group's Board of Direc-  tors and top management. NTG is committed to  comply with these regulations and set targets  for gender composition in top management.  While the transport industry traditionally has  a lower share of women, which can impact  recruitment and retention, NTG is dedicated  to address this challenge. We understand  that achieving these targets is crucial for our  reputation and compliance, and we are actively  working towards fostering a more inclusive  and diverse workplace.  No Positive Material Impacts  NTG has not identified any positive material impacts  within its workforce.  MDR P, S1-1  Policies related to own workforce  The employee Code of Conduct and ESG & Diversity Policy  defines how to work responsibly and our business practices.  It aims to establish standards concerning working conditions,  employment practices, occupational health and safety (including  prevention of work-related injuries) and human rights (including  the prohibition of forced, exploitative and child labour).  The purpose of the employee Code of Conduct is to provide  clear guidelines for employees on how to act in a legally and  morally correct manner in various situations. It applies to all  entities and employees of the NTG Group and sets out princi-  ples for carrying out their jobs, especially when ethics and legal  boundaries are challenged. The Code of Conduct aims to ensure  that all employees take personal responsibility and live up to the  ethical expectations described, thereby preserving the reputa-  tion and integrity of NTG.  The Code of Conduct and ESG & Diversity Policy applies to all  entities and employees of the Group and sets out principles for  carrying out their jobs, especially when ethics and legal bound-  aries are challenged. NTG ensures that its workforce can com-  prehend the Code of Conduct through regular training sessions,  helping employees understand and adhere to the guidelines.  The Board of Directors holds the highest level of accountability  for the policies, while the Group Executive Management is re-  sponsible for their daily implementation. Additionally, local man-  aging directors of NTG entities are tasked with implementing  these policies locally and guiding our employees to make proper  decisions and act in accordance with the Code of Conduct for  employees and ESG & Diversity Policy.  MDR A, S1-4  Taking action on material impacts on own workforce,  and approaches to managing material risks and pursuing  material opportunities related to own workforce, and  effectiveness of those actions  Work-related injuries prevention  At NTG, the safety of our employees is our highest priority. We  closely monitor the performance indicators (KPIs) related to  workplace accidents and absence due to such incidents.  Given the nature of our work, which involves long-distance  transportation in dense traffic, handling heavy machinery and  goods, and coordinating with various stakeholders, the risk of  accidents is significant. In the transport industry, such incidents  can sometimes have fatal outcomes. Thankfully, no employee in  NTGâs history has experienced such a tragedy, and we are com-  mitted to maintaining this record. Our top priority is preventing  severe accidents.  Despite our efforts, we do record incidents each year where  employees sustain injuries and we record absence related to  these injuries. To mitigate these occurrences, we have estab-  lished local incident procedures. Every incident and accident  are documented and analysed to determine the cause. Local  management then decides if any procedures need to be revised  or optimised based on these findings. While any harm to an  employee is unacceptable, we recognise that the severity of  an accident often correlates with the length of the employeeâs  absence. Therefore, we have set targets to reduce both the rate  of work-related incidents and the number of days of absence  due to such accidents annually.  Diversity in NTG  At NTG, we are committed to building a diverse workforce and  management team, encompassing a range of ages, nationalities,  genders, and backgrounds. We believe that diversity is a source  of strength and innovation for our organisation. Our global and  local operations enable us to collaborate with individuals from  various cultures and backgrounds, bringing a wealth of skills and  experiences to our team. Diversity enhances our creativity and  problem-solving abilities, leading to more innovative solutions  for our customers. It fosters a more inclusive and dynamic work  environment where different perspectives are valued and re-  spected. This variety of viewpoints helps us better understand  and meet the needs of our diverse customer base.  Our ESG & Diversity Policy underscores our dedication to  enhancing employee diversity within NTG. We strive to attract  and retain talented employees by providing opportunities for  growth and development. We ensure fair and objective treat-  ment of all employees and applicants, based on criteria relevant  to each specific position. This commitment applies to both em-  ployee and management roles and reflects our zero-tolerance  approach to any form of discrimination.  NTG will evovle a more focussed strategy to increase our  focus on relevant and more concrete actions to be followed to  increase diversity in our organisation.  Data privacy  NTG is a company that operates in the transport and logistics  industry, where data is an asset. Data is collected from various  sources, such as vehicle tracking systems and video surveillance  systems. This data helps us to improve our services, optimise  our operations and meet our customers' needs. However, data  also comes with responsibilities.  We must respect the privacy and rights of the people whose  data we process, and we need to protect the data from unau-  thorised access or misuse. That is why we continuously monitor  applicable data protection principles and additional safeguards  put in place by our information technology and security system  to guide our actions and decisions regarding data privacy and  security.  One of the ways in which we implement our data ethics policy  is by complying with the relevant data protection laws, such as  the EU General Data Protection Regulation (GDPR). We have  established a data protection system that ensures that we only  collect, store, use, and share personal data for legitimate pur-  poses, and that we delete or anonymise it when it is no longer  needed.  We also use a data privacy software that helps us to manage  our support the management of personal data processes and  practices in a transparent and efficient way. Furthermore, we  train our employees on how to handle personal data in a secure  and respectful manner.  MDR-T, S1-5  Targets related to managing material negative impacts,  advancing positive impacts, and managing material risks  and opportunities  NTG is committed to setting, measuring, monitoring, and re-  viewing diversity and health and safety targets, and acting when  there are deviations from expected progress.  Health and safety  We have set a target to reduce both the rate of work-related  incidents and the number of days of absence due to work-relat-  ed accidents every year. The purpose of the target is to improve  year by year. Tracking and performance against the target is  conducted at Group level. If a company reports increasing  work-related injuries the results will be evaluated together  with the local management and measures for improvement and  progress is agreed.  Additionally, the work-related incidents can have serious  consequences, and sometimes even fatal outcomes, for those  involved. Thankfully, no employee in NTG's history has expe-  rienced such a tragedy, and we are determined to keep it that  way. Therefore, we have set a target to ensure that NTG will  have no fatalities among our employees and the target has no  expiration.  Diversity  We consider the diversity of our employees a strength, particu-  larly in achieving a more balanced gender distribution. NTG aim  to increase the gender diversity relative to the industry stand-  ard and has set a target to enhance the representation of the  underrepresented gender in the Board of Directors. Our ESG &  Diversity Policy outlines our commitment to strengthening the  employee diversity within NTG. We aim to attract and retain  talented employees by offering them opportunities for growth  and development. We treat all employees and applicants fairly  and objectively based on the criteria relevant to the specific po-  sition. This applies to both employee and management positions  and reflects our zero-tolerance approach towards discrimination  of any kind.  For other levels of management including executive manage-  ment and management who reports directly to the executive  management, we aim to reach a representation of 10% of the  underrepresented gender in 2027 at the latest. Tracking and  performance against the target is conducted at Group level on a  yearly basis to evaluate performances and development.  Data privacy  Our protection of data is based on widely known and accepted  cybersecurity frameworks, such as ISO 27001 and CIS Controls,  and we use data protection compliance tools to map the data  flow of personal data between us and third parties, to increase  data use transparency and accountability.  We will continue to enhance our knowledge of how data and  artificial intelligence systems impact the transport and logistics  industry, and we will collaborate with our stakeholders to  implement best practices regarding data ethics. Further, we will  provide training to our employees to ensure that we handle data  in a responsible and sustainable way.  NTG has not yet established specific and measurable targets  to mitigate its material impact on data privacy but intends to  investigate further to be able set up relevant and realistic goals  for possible improvements of the impact.  S1-2  Processes for engaging with own workforce and workers'  representatives about impacts  NTGâs global reach is supported by a decentralised organisation-  al structure and locally rooted expertise in multiple countries,  enabling us to manage any shipment, regardless of size, desti-  nation, or complexity. We leverage advanced technology plat-  forms to deliver efficient, reliable, and cost-effective solutions  tailored to our customersâ specific logistics needs and prefer-  ences. However, technology alone is not enough to achieve our  goals. We also need passionate and purposeful employees who  share and understand NTGâs vision and values.  Our employees are the driving force behind our success. They  interact with our customers and suppliers daily, executing our  strategies and plans while understanding the impact of their  work on our customers, the company, and the societies in  which we operate. NTGâs employees strive for excellence in  everything they do, always seeking to create positive outcomes  for all stakeholders. Their skills and qualifications are essential  for achieving our goals, and every employee plays a vital role in  fulfilling the NTG Groupâs vision of being the preferred choice  for transport solutions for our customers.  The Executive Management has the responsibility for commu-  nicating our position on these matters in our ESG & Diversity  Policy and Code of Conduct for Employees. NTG does not have  any Global Framework Agreement established. Our company  values guide our employees in respecting freedom of associ-  ation, promoting equal opportunities and diversity in employ-  ment, and ensuring a high priority for a safe and healthy work  environment.  This forms the basis for the daily dialogue between employ-  ees and management in handling day-to-day operations and  everyday challenges. Additionally, an employee satisfaction  survey is conducted on a yearly basis among ISO certified NTG  companies, along with other internal surveys, to provide NTG's  management with insights into employee satisfaction on various  relevant topics such as health & safety, diversity and privacy  among other topics.  NTG also collects data on work accidents and various diversity  metrics, which forms the basis for relevant actions to achieve  further improvements. The results of the employee satisfaction  survey are openly presented and results discussed with em-  ployees to continuously improve the working conditions. NTG  aims for an employee satisfaction score that are above those of  comparable companies.  Regarding health and safety issues, engagement is conducted  via local employee Health & Safety representatives that are  appointed at various sites, or through the outcomes of investi-  gations of local health and safety-related incidents.  S1-3  Processes to remediate negative impacts and channels for  own workforce to raise concern  NTG can influence its employees through its well-established  company culture, benefits, policies, and practices. As a service  provider, NTG depends on skilled and qualified employees for  success. Therefore, employee well-being and engagement are  crucial for achieving our strategy and targets.  NTG encourages its employees and other stakeholders to speak  up if they become aware of a breach of law or a serious breach  of NTG's Code of Conduct, including employee matters such as  health and safety and data privacy.  Should employees become aware of any unethical conduct  that is deemed in breach with NTG's policies they are urged to  report this immediately to own manager, other management or  to NTG Group Legal. Health and safety and data privacy issues  could also be filed in NTG's whstleblower system. The system is  administered by an independent third party to ensure anonym-  ity. As a part of our Whistleblower policy NTG have processes  in place to ensure that employees reporting possible violations  in good faith will not be subject to retaliation and that any  information provided via the system is handled in a confidential  manner.  We make sure employees know about these mechanisms and  how to use them by providing training during onboarding, train-  ing activities and through regular updates from management.  NTG is committed to comply with all applicable laws and  regulations that govern our business activities. If NTG causes a  material negative impact on any employees in its own work-  force, NTG will provide remedy to the involved employee and  compensate, if required.  ESRS 2 S1-6  Characteristics of the undertaking's employees  ESRS ID  2024  S1-6  Employees per contract type and gender  Permanent female employees (FTE), number  844  Permanent male employees (FTE), number  1,879  Temporary female employees (FTE), number  0Temporary female employees (FTE), number  0Non-guaranteed hours female employees (FTE), number  0Non-guaranteed hours male employees (FTE), number  0Total employees (FTE), number  2,732  S1-6  Country representation, employees (headcounts)  Germany  866  Denmark  726  Sweden  331  Other  1,009  Total (head count), number of employees  2,932  S1-6  Employee turnover  Employee's who left NTG (FTE), number  516  Employee turnover (%)  18.8  Accounting policies  Full-time-equivivalent (FTE)  Full-time-equivivalent is an employee whose weekly working hours are established in accordance with national legislation  and customary practices pertaining to agreed-upon working time.  Headcounts  Headcounts are defined as employees with a standard or temporary contract with NTG, including employees working, part-  time, full-time and with non-guarantees working hours.  Employees per contract type and gender  Number of employees per contract type and divided by gender (FTE). Numbers reported at the end of the reporting period.  NTG has not collected data on employee's gender based on head count information in 2024.  Country distribution  The total number of employees (head count) split into country by countries in which NTG has 50 employees or more repre-  senting at least 10 % of the total number of employees. Numbers reported at the end of the reporting period.  Employee turnover  Number of employees (FTE) leaving NTG during the year including voluntary and involuntary leavers. The turnover rate is  based on the total share of employees (FTE) leaving within the year divided by the total number of employees.  S1-6  Characteristics of the workforce  NTG employs more than 2,700 people, with over 65% working  in freight forwarding and administrative support roles. The  remaining employees are primarily involved in handling our  customers' goods in our terminals and warehouses.  Our workforce spans across all age groups, with more than 27%  of employees being over 50 years old. Additionally, 19% of our  employees have been with their respective NTG subsidiary for  11 years or longer. Absence due to illness decreased among  both employee groups, resulting in an overall reduction for the  year.  S1-9  Diversity metrics  NTG is committed to secure a diverse workforce and manage-  ment team, represented by a wide range of ages, nationalities,  genders, and backgrounds. Diversity is a source of strength and  innovation for our organisation. Our global and local operations  enable us to collaborate with individuals from various cultures  and backgrounds, bringing a wealth of skills and experiences to  our team. Diversity enhances our creativity and problem-solving  abilities, leading to more innovative solutions for our custom-  ers. It fosters a more inclusive and dynamic work environment  where different perspectives are valued and respected. This  variety of viewpoints helps us better understand and meet the  needs of our diverse customer base.  Our ESG & Diversity Policy underscores our dedication to  enhancing employee diversity within NTG. We strive to attract  and retain talented employees by providing opportunities for  growth and development and ensure a fair and objective treat-  ment of all employees and applicants, based on criteria relevant  to each specific position. This commitment applies to both em-  ployee and management roles and reflects our zero-tolerance  approach to any form of discrimination.  Executive management diversity  Gender distribution at Executive Management level in NTG  includes the Executive management and employees reporting  directly to them with managerial responsibilities. In 2024, the  Executive Management team and their direct reports with man-  agerial responsibilities consisted of 11 employees with a gender  distribution of 90.9% males and 9.1% female.  S1-14  Health and safety metrics  Ensuring the safety of our employees is paramount. Conse-  quently, some of our key performance indicators (KPIâs) focus on  minimising incidents that could cause physical or psychological  harm during their daily tasks. Our primary goal is to safeguard  the well-being of all employees and protect them from potential  safety hazards and severe injuries in the workplace.  Given the nature of our work, which involves long-distance  transportation in dense traffic, handling heavy machinery and  goods, and coordinating with various stakeholders, the risk of  accidents is significant. In the transport industry, such incidents  can sometimes have fatal outcomes. Fortunately, no employee  has experienced such a tragedy, and we are committed to keep-  ing that way. This commitment is reflected in our top priority:  preventing severe accidents.  S1-9  Composition of NTG's management levels  ESRS ID  2024  S1-9  Top management  Number  Percent  Proportion of female Top managers  19.1  Proportion of male Top managers  10  90.9  More characteristics of NTG's employees  S1-9  Age distribution  Distribution of employees under 30 years old  719  24.5  Distribution of employees between 30 and 50 years old  1,416  48.3  Distribution of employees over 50 years old  797  27.2  Total employees (headcounts)  2,932  100  Accounting policies  Top management  Number of female and male top managers with employee responsibility and relative to total Executive managerial employees with personnel  responsibility at year end. Top management in NTG are defined as Group's Executive management and employees with employee management  who report directly to Executive management team.  Age distribution  Reported number of employees by age group and relative to employees at year end.  S1-14  Health and safety information  ESRS ID  2024  Health and safety information  S1-14_01  Own workforce covered by health and safety management systems  NA  S1-14_02  Number of fatalities in own workforce as result of work-  0related injuries and work-related ill health  S1-14_03  Number of fatalities as result of work-related injuries and work-related  0ill health of other workers working on undertaking's sites  S1-14_04  Number of recordable work-related accidents for own workforce  25  S1-14_05  Rate of recordable work-related accidents for own workforce, per million working hours  4.5  S1-14_06  Number of cases of recordable work-related ill health of employees  0S1-14_07  Number of days lost to work-related injuries and fatalities from work-related  524  accidents, work-related ill health and fatalities from ill health realted to employees  Rate of days lost to work-related injuries resulting in more than one day of absence per  93.3  million working hours scheduled in the year, all employees per million working hours  Accounting policies  Accounting policies for S1-14 â Health and safety information  S1-14_01  Large parts of NTG's own workforce are covered by different locally maintained health and safety  management systems, but information on coverage in percentage can not be collected presently.  NTG will will work to improve this in 2025.  S1-14_02  Reported number of fatalities in own workforce as result of work-related injuries and work-related  ill health.  S1-14_03  Reported number of fatalities as result of work-related injuries and work-related ill health of other  workers working on NTG's sites.  S1-14_04  Reported number of recordable work-related accidents for own workforce. Work-related acci-  dents or injuries arise from exposure to hazards at work.  S1-14_05  The sum of lost time work-related accidents with more than one day of absence reported for own  workforce, per million working hours.  S1-14_06  Reported number of cases of recordable work-related ill health of employees.  S1-14_07  Number of days lost to work-related injuries and fatalities from work-related accidents, work-relat-  ed ill health and fatalities from ill health realted to employees  Rate of lost work days  The sum of days lost to work-related accidents for own workforce resulting in more than one day  due to work-related  of absence per million working hours scheduled in the year.  injuries  Number of working  Number of working hours is measured on the basis of prescribed working hours for employees  hours  excluding national and agreed holidays, and days off.  ESRS ID  2024  Incidents, complaints and severe human rights impacts  S1-17_02  Number of incidents of discrimination  2S1-17_03  Number of complaints filed through channels for people in own workforce to raise concerns  2S1-17_04  Number of complaints filed to National Contact Points for OECD Multinational Enterprises  0S1-17_05  Amount of material fines, penalties, and compensation for damages as  0result of violations regarding social and human rights factors  S1-17_08  Number of severe human rights issues and incidents connected to own workforce  0S1-17_09  Number of severe human rights issues and incidents connected to own workforce that are cases  0of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises  S1-17_11  Amount of material fines, penalties, and compensation for severe human  0rights issues and incidents connected to own workforce  Despite our efforts, we do record incidents each year where  employees sustain injuries. To mitigate these occurrences, we  have established local incident procedures. Every incident and  accident are documented and analysed to determine the cause.  Local management then decides if any procedures need to be  revised or optimised based on these findings. While any harm to  an employee is unacceptable, we recognise that the severity of  an accident often correlates with the length of the employeeâs  absence. Therefore, we have set targets to reduce both the rate  of work-related incidents and the number of days of absence  due to such accidents annually.  S1-17  Incidents, complaints and severe human rights impacts  In 2024 NTG recorded two incidents of discrimination that  related to violations of NTG's Code of Conduct for Employees  within its own workforce. These incidents was reported in  NTG's whistleblower system and was processed according to  our policies. Further, two incidents related to human resource  issues were reported through other channels. These incidents  were handled by Group Management in collaboration with the  local employees involved, leading to a clarification of coopera-  tion principles and procedures.  Accounting policies  Accounting policies for S1-17  â Incidents, complaints and severe human rights impact  S1-17_02  Number of incidents reported by employees in own workforce about incidents of discrimination and/or harassment due  to gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of  discrimination involving internal and/or external stakeholders arcoss operations.  S1-17_03  Number of cases field through channels for employees in own workforce to raising concerns about incidents of discrimina-  tion and/or harassment due to gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation,  or other relevant forms of discrimination involving internal and/or external stakeholders arcoss operations. Other cases not  relating to above mentioned subjects can also be filed through this channel.  S1-17_04  Information received by NTG on number of complaints filed to National Contact Points for OECD Multinational Enterprises.  S1-17_05  Reported amount of material fines, penalties, and compensation for damages as result of violations regarding social and  human rights factors.  S1-17_08  Reported number of severe human rights issues and incidents connected to own workforce.  S1-17_09  Reported number of severe human rights issues and incidents connected to own workforce that are cases of non-respect of  UN Guiding Principles and OECD Guidelines for Multinational Enterprises.  S1-17_11  Reported amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to  own workforce.  ESRS S2  Workers in value chain  As an asset-light freight forwarder, we depend significantly on third-party suppliers to provide our services and solutions. Suppliers and their  employees, acting on behalf of NTG, must be capable of handling goods and transport units (e.g., road trailers or sea freight containers)  while adhering to agreed-upon customer-specific quality criteria, procedures.  NTG is highly dependent on its suppliers and  its employees for several important opera-  tions in NTG's value chain. The supplier and  its employees must be able on behalf of NTG  to handle goods and the transport unit (e.g.  trailer or sea freight container) and comply  with agreed customer-specific quality criteria  and procedures and the NTG's Supplier Code  of Conduct. In addition, the supplier must be  able to handle and mitigate any deviations in  cooperation with NTG and/or the customer as  well as any other suppliers in the value chain.  Interest and views of our value chain workers  are reflected in ESRS 2, SBM-2 on p. 54.  SBM-3  Material impacts, risks and opportunities  Suppliers must be able to manage and mitigate  any deviations in collaboration with NTG,  the customer, and other suppliers within the  value chain. NTGâs materiality assessment has  identified our impact on workers in its value  chain, particularly concerning safety for those  providing these services.  NTG's impacted workers in our value chain  could be found among our suppliers delivering  different transport services and solutions.  Air & Ocean suppliers generally operate on  fixed schedules for loading, unloading, and  departure, primarily transporting standard-  ised goods in containers. These suppliers are  typically larger regional or global companies  with their own back-office support. Their  employees work at freight terminals in ports  or airports, where NTGâs customersâ goods are  delivered by road transport suppliers, handled,  and prepared for transport on the supplierâs  vessel. Non-standardised goods are handled  by a different group of air and ocean suppliers  specialising in such transport. These suppli-  ers are usually local or regional, with a small  portion originating from outside Europe. Com-  panies in this group are generally much smaller  than those transporting standardised goods.  Road suppliers are typically managed more  directly by NTG employees to meet customer  requirements. NTGâs pool of road suppliers  generally consists of hundreds of smaller  haulier companies with only a few trucks in  operation and limited back-office support.  Additionally, road suppliersâ employees usually  work with their own equipment at customer  sites and NTG locations to pick up and deliver  trailers with customer goods, as well as collect  and deliver trailers at NTG customersâ produc-  tion or storage facilities. The actual transport  of the customerâs goods occurs on the public  road network.  Road suppliers can be categorised into  different groups. The first group consists of  dedicated road suppliers who allocate one or  more vehicles exclusively to service NTG com-  panies and handle the majority of NTGâs road  transports. Another group of road suppliers  is more loosely connected to NTG companies  and is typically used during busy periods when  the dedicated road suppliers cannot provide  sufficient capacity. The third group of suppli-  ers operates on the spot market and has only  a loose association with NTG.  Own  IRO  Upstream  operation Downstream  Health and Actual negative  â8safety  Impact  The different groups of suppliers typically orig-  inate from European countries and/or the US.  Health and safety for suppliers and its  employees  NTG identifies a material negative impact in regard  to health and safety for suppliers and its employ-  ees handling and transporting goods. The impact  is evaluated to concern the physical handling of  goods that should be transported on behalf of  NTG's customers. The physical transport is though  performed by the supplier and its employees.  No opportunities identified  NTG has not identified any opportunities related to  value chain workers.  ESRS S2  Policies related to  value chain workers  We hold our suppliers to the same high standards as our  employees, as outlined in our Code of Conduct for Suppliers.  S2-1  The Board of Directors holds the highest  level of accountability for the policy, while  the Executive Management is responsible for  its daily implementation. Additionally, local  managing directors of NTG entities are tasked  with local implementation when in contact  with suppliers.  The policy forms the basis of all actions and  activities carried out in NTGâs name and  provides information and guidance on ethical  conduct towards various stakeholders and  addresses key issues such as no tolerance to  bribery and corruption, human and labour  rights, occupational health and safety (includ-  ing prevention of work-related injuries) and  whistleblower protection. NTG's suppliers  must be able to manage and mitigate any  deviations in collaboration with NTG, the  customer, and other suppliers within the value  chain. Our policy shares the interests of our  suppliers to comply with relevant regula-  tion including health and safety regulations.  Further, the policy outlines our commitment  to engage with affected suppliers as we make  our whistleblower system open to them and  to remedy any adverse impacts we may cause  or contribute to.  The policy is applicable to all suppliers and  business partners who operate with or on  behalf of NTG, including hauliers, agents,  suppliers, sub-suppliers, business partners or  distributors. The policy is in addition to appli-  cable laws and general principles of law in the  jurisdictions where our suppliers operate.  NTG ensures that its suppliers and business  partners are informed about the Code of  Conduct during the procurement process.  Adherence to the Code of Conduct is a crucial  part of our supplier selection criteria. We  rely on third-party suppliers for our services  and solutions, and by thoroughly vetting our  suppliers, we can identify risks and determine  how to manage them before and during our  collaboration.  Our global rules for managing supplier risks  apply to all purchases and supplier relation-  ships. Many of our key supplier relationships  are managed by central teams at the Group or  within our divisions and entities. This includes  major global agreements, EU road haulier  procurement, and air and ocean carrier pro-  curement. In addition to our central processes,  local operations handle local procurement  and supplier contracts, ensuring due diligence  is conducted for these relationships. We  are committed to continuously improve our  processes to ensure that our suppliers align  with the standards we have set towards our  business and our partners.  NTG is a signatory to the UN Global Com-  pact and supports the Ten Principles on  human rights, labour, environment and anti-  corruption. NTG's policy are based on the ten  universally principles within human rights,  environment and anit-corruption.  NTG's Code of Conduct for Suppliers to NTG  forms the basis of all actions and activities  carried out on behalf of NTG and provides  information and guidance on ethical conduct  towards various stakeholders.  The Code of Conduct reflects NTGâs com-  mitment to act responsibly with all business  partners, including the commitment to respect  human and labour rights as well as providing  guidance on our prohibition towards corrup-  tion. We expect our suppliers to actively en-  sure that the supplierâs own agents, sub-sup-  pliers and subcontractors also comply with the  requirements of this Code of Conduct.  NTG expects that its suppliers comply with  all applicable foreign trade control laws and  regulations imposed by the United Nations,  the European Union, the United Kingdom, the  United States of America, or other relevant  regulator, which apply to their business or  services.  Health and safety  NTG expects that its suppliers provide safe  and healthy working environments for all their  employees. NTG expects that its suppliers  have implemented procedures to ensure that  they apply with all applicable laws and have  taken appropriate measures to prevent the  use and abuse of alcohol, drugs, or other  unlawful substances by its personnel. In case  of fatal accidents and/or serious injuries which  potentially could lead to claims or liability  for NTG or NTGâs customers, suppliers are  expected to report these as soon as possible  to their contact person at NTG.  No discrimination  NTG expects our suppliers to support equal  opportunities for all employees and business  partners and to recognise and work actively  against discriminatory treatment based on  race, gender, religion, age, nationality, sexual  orientation, disability, political orientation,  ethnic or social background.  ESRS S2  Engaging with value chain workers  NTG's processes for engaging with value chain workers depends on its different suppliers  delivering various services and solutions.  S2-2  Processes for engaging with value chain workers about  impacts  Suppliers deliver the physical transport of NTG's customers  goods that is the primary service NTG offers. NTG is highly de-  pendent on its suppliers and its employees for several important  operations in NTG's value chain. The supplier and its employ-  ees must be able on behalf of NTG to handle goods and the  transport unit (e.g. trailer or sea freight container) and comply  with agreed customer-specific quality criteria and procedures.  In addition, the supplier must be able to handle and mitigate any  deviations in cooperation with NTG and/or the customer as well  as any other suppliers in the value chain.  In general, suppliers are affected by NTG's policies and its  guidance on how NTG expects its suppliers to behave in  contact with other stakeholders. As some suppliers perform  their services under the NTG brand and/or with NTG branded  equipment it can have a great effect on the NTG brand in case  of non-compliance.  NTG's Code of Conduct for Suppliers reflects NTGâs commit-  ment to act responsibly with all business partners, including the  commitment to comply with health and safety regulations. We  believe that by focusing on the values as described in the policy,  NTG will strengthen the relationships with its suppliers and  sustainable business relationships will be created. Further, we  expect our suppliers to actively ensure that the supplierâs own  agents, sub-suppliers and subcontractors also comply with the  requirements of this Code of Conduct.  The divisional management in NTG - CEO Road & Logistics  and CEO Air & Ocean - has the operational resopnsibility for  ensuring a proper and adequate engagement takes place with  engaged suppliers. The divisional management reports to the  Executive management.  NTG expects that suppliers in case of fatal accidents and/or  serious injuries which potentially could lead to claims or liability  for NTG or NTGâs customers, suppliers are expected to report  these as soon as possible to their contact person at NTG. Sup-  pliers and its emplyees also have the possibility to report any  possible cases through NTG's whistle-blower portal. Whenever  inputs from suppliers or its employees comes to NTG through  the sources available for engagement mentioned, NTG handles  these according to its policy.  An example of engagement was the introduction of the EU  Mobility Package that included rules on driving times and rest  periods, working hours, posting and cabotage.  Most of the requirements under the EU Mobility Package apply  to the haulier as the employer of the driver. However, due to un-  certainty of national implementation of for example the Posting  of Workers Directive and the additional requirements on the  hauliers, the implementation led to increased freight rates and  pressure on the truck capacity. To ensure truck capacity and  hauliers compliance with the new requirements, NTG was re-  quired to make changes to planning schedules and strengthened  the cooperation with its hauliers. To this effect, we provided  guidance to our subcontractors on the new requirements, up-  dated our terms and conditions and updated our Code of Con-  duct for Suppliers. As compliance with the EU Mobility Package  is increasingly monitored by our customers, audit processes of  our hauliers was initiated  S2-3  Processes to remediate negative impacts and channels for  value chain workers to raise concerns  Suppliers and/or their employees are encouraged to report any  concerns or complaints related to any possible breach of NTG's  Code of Conduct for Suppliers including health and safety  issues. This is communicated to all suppliers when concluding  contracts and agreements.  ESRS S2  Raising concerns can happen directly when engagement occurs.  If the supplier and/or its employees are uncomfortable with  addressing the concern directly or wants to do it anonymously  they as all other stakeholders can address this through NTG's  third-party handled whistleblower portal.  NTG will always handle concerns or needs raised directly from  suppliers and/or its employees accordingly. NTG will evaluate  the raised concern or need and initiate a dialouge with the raiser  to remediate health and safety issues and any other matter  raised.  S2-4, MDR-A, S2-5, MDR-T  NTG has not yet established specific actions and targets to  mitigate its material impact on suppliers and its employees.  Since we have not yet systematically collected information  directly from our suppliers about the number of specific and  possible incidents within health ansd safety, we will try to form  a better overview of the extent of the impact together with our  suppliers. This is in order to be able to determine and set up rel-  evant actions and realistic goals for possible improvements. This  process will be initiated in 2025, after which NTG expects to  be able to set up specific actions and relevant goals for possible  improvements.  ESRS G1  Business conduct  Governance framework  NTG is committed to complying with all applicable laws and regulations  that govern our business activities. As a publicly listed company operating  in different countries, we face various legal and regulatory challenges.  Moreover, our reliance on independent carriers exposes us to both internal  and external compliance risks.  IRO-1, G-1  Material impacts, risks and opportunities  and the process to identify  NTG has used the same approach as described  in IRO-1 on page 57 to identify and assess  material impacts, risks, and opportunities in  relation to actual and potential pollution-relat-  ed impacts from NTG's activities in own oper-  ations as well as in upstream and downstream  value chain activities.  SBM3, G1  Most countries in which NTG operates have  laws prohibiting corruption of government of-  ficials, officials of other countries and private  commercial persons. In addition to local laws,  international anti-corruption treaties applies  in many of the jurisdictions where NTG is  present. These regulations prohibit both  direct and indirect payments, as well as offers  and promises to pay or give anything of value  for a corrupt purpose to obtain a business  advantage.  Despite local and global anti-corruption regu-  lation NTG could face risks of corruption and  bribery as some of our activities takes place  in certain countries with a higher risk. This  includes the use of facilitation payments for  permits and cargo clearance etc.  As a global company with a wide value chain,  the risk of being involved in corruption and/  or bribery was identified and assessed to be a  materiel risk for NTG. It is important for NTG  to maintain its reputation in the market, and  to avoid heavy fines and penalties that could  be a result in case of violations.  In our process for identifying and assessing  IRO's connected to business conduct, we used  input from the compliance programme and  assessed this against our internal subject-mat-  ter experts used as proxies for the relevant  stakeholder groups. Other sub-topics has  been assessed but was not found material in  NTG's 2024 double materiality process.  ESRS 2  The role of the administrative,  supervisory and management bodies  NTG has embedded its governance framework  within the management and board structure  ESRS 2 GOV-1  At NTG, responsible and ethical business  conduct is deeply embedded in our corporate  culture and organisation. This commitment is  reflected across our entire organisation, with  various bodies and employees dedicated to  building a strong framework that minimises  the risk of corruption and bribery within our  value chain.  The Board of Directors  The Board of Directors is responsible for the  overall strategic management and organisation  of the Groupâs activities as well as the Groupâs  financial and material matters, here including  the business conduct matters. Further, they are  responsible for setting the policy, strategy, and  objectives in the sustainability area, including  business conduct.  The composition of the Board of Directors  and its permanent committees is intended to  ensure that the Board of Directors has a di-  verse competency profile, enabling the Board  of Directors to perform its duties, including  a variety of business conduct matters, in the  best possible manner.  The Executive Management  The Executive Management is responsible for  NTGâs day-to-day management, including the  compliance of NTG and its operations with  applicable legislation, the Board of Directorsâ  guidelines and instructions, including imple-  mentation of the strategy set by the Board of  Directors, and for disseminating information  on NTGâs operations to the Board of Direc-  tors. The Executive Management is respon-  sible of the content of the Code of Conduct  for Employees and the Code of Conduct for  Suppliers and other business conduct related  policies implemented in NTG. All policies are  communicated from the top by the CEO.  The composition of the Executive Manage-  ment is intended to ensure that business  conduct matters are handled according  to the strategy laid down by the Board of  Directors  ESRS 2 â G1  KPIs  2024 metric  Progression  Read more  All salaried employees  21% of employees  In 2024, we updated the Code of Conduct training material, Page 110  must receive Code of  and therefore exisitng employees did not conduct full  Conduct training every  training session. All new hires completed the training. We  year.  will resume our training for all employees in 2025.  We commit to perform  Completed our  We performed ongoing control on the group of suppliers  Page 111  yearly compliance  yearly compliance  with sanctions and embargoes as well as compliance checks  audits and spot checks  spot checks  of groups of new suppliers  of suppliers performed  through remote audits,  questionnaires and  checklists.  We commit to perform  Completed our  We conducted our second legal compliance risk assessment Page 110  yearly compliance  yearly compliance  across all NTG entities. The results of the 2024 risk  spot checks of NTG  spot checks  assessment informed the mitigation plan, ensuring a  entities to monitor the  continued focus on high-risk entities and legal compliance  effectiveness of our  areas.  mitigating measures  under NTG's Legal  Compliance Program.  Own  IRO  Upstream  operation Downstream  9Prevention and detection including training  Risk  ââAdministrative  The Group functions managed by the Execu-  tive Management are responsible for devel-  oping, implementing and maintaining the poli-  cies, actions, targets, and metrics for business  conduct based on long industrial experiences  with implementing business conduct.  To ensure that our Code of Conduct and other  elements of our Legal Compliance Program  are well understood and followed by all our  employees, we have made online training a  high priority. Group Legal monitors the partic-  ipation of all employees in the online training.  New employees are required to read NTG's  Code of Conduct for Employees and take  part in various training sessions related to our  operational systems.  NTGâs network of compliance champions  One of the key factors for NTG's success and  integrity is having a strong compliance culture  across the NTG Group. To support this goal,  a network of local advisors was established  in our subsidiaries in 2020. The compliance  champions are the first point of contact  for any legal compliance-related questions,  especially on anti-corruption, foreign trade  controls, and competition laws.  The network has the backing of our Group  Management and helps to embed legal  compliance topics into our business processes.  Moreover, they help local management to  align day-to-day business operations with  legal compliance requirements, assist with  increasing our legal compliance presence in  the workforce, and encourage local employees  to raise compliance issues and concerns.  In 2024, in total 29 compliance champions  were appointed. They are located in 18  different countries with the purpose of raising  awareness about the various changes in both  legislation and internal controls.  Functions at risk in NTG  NTG has assessed that certain groups of  employees who carry out functions such as  sales and business development, who handle  the negotiation and conclusion of contracts  with customers, are most at risk in respect of  corruption and bribery. In addition to this, all  new employees are also at this risk as they  must familiarise themselves with NTG's rules  of conduct upon employment  ESRS G1  Business conduct policies and corporate culture  To address our business conduct related risk and challenges, we have established  a Legal Compliance Program that encompasses anti-corruption, foreign trade  controls, competition laws, and data privacy. This program aims to prevent, detect,  and address any potential legal violations.  MDR-P, G1-1  Code of Conduct for Employees  The Code of Conduct for Employees defines our dedication to  responsible business practices and forms the basis for NTG to  build a strong compliance corporate culture. It aims to establish  standards for our employees regarding topics such as conflicts  of interest, trade secrets and confidential information, bribes  and facilitation payments, foreign trade control(s) and gifts and  favours. Introduction of the Code of Conduct is mandatory for  all members of NTGâs workforce.  NTG rest assure that all employees of the Group every day  strive to deliver the best services and be the best possible  colleagues. NTG also appreciate that from time to time, all  employees find themselves in situations where they are unsure  of which direction to take in order to act in a way that is legally  and morally correct and servicing NTG's interest best. NTG has  therefore compiled a Code of Conduct for Employees to provide  clear guidelines for a range of specific situations. The most  important success factor for the Code of Conduct is that all  employees take personal responsibility and live up to the ethical  expectations described. At NTG, we manage our business in  compliance with all the applicable laws and regulations of the  countries in which we operate. This Code of Conduct does not  and cannot cover every possible situation that we may face, nor  does it describe every law, policy or standard with which we  must comply. However, it does provide a useful framework for  making practical, lawful and ethical decisions that protect the  interests of NTG, its employees, contractors and stakeholders.  Code of Conduct for Suppliers  The Code of Conduct for Suppliers forms the basis of all actions  and activities carried out in NTGâs name and provides informa-  tion and guidance on ethical business conduct towards various  stakeholders. Further, it reflects our commitment to sustain-  ability in areas such as human rights, anti-corruption, supplier  relationships, labour standards, and environmental responsibil-  ity. We require our suppliers to adhere to the same values and  principles as NTG. We monitor supplier compliance through  spot checks, subcontractor audits, and every other year, we  perform internal risk assessments.  Responsible behaviour is a part of NTGâs core values, and cus-  tomers and other stakeholders expect NTG to conduct business  in a responsible manner. We believe that by focusing on the val-  ues as described in this Code of Conduct for Suppliers, NTG will  strengthen the relationships with its suppliers, and sustainable  business relationships will be created. We expect our suppliers  to actively ensure that the supplierâs own agents, sub-suppliers  and subcontractors also comply with the requirements of the  Code of Conduct for Suppliers.  The Code of Conduct is available on NTGâs website, and it is  communicated to suppliers upon completion of contracts and  agreements with suppliers. The code is available in 12 different  languages.  ESRS G1  Prevention and detection of corruption and bribery  NTG has clear proccesses for risk assessment and an independent whistleblower  system to prevent, detect, and address compliance challenges  G1-3  Risk Assessment â A Fundamental Element  NTGâs internal risk assessment is a vital tool for effectively and  adequately addressing risks. This assessment identifies areas  where there may be potential non-compliance with laws, regula-  tions, and internal rules. Additionally, it evaluates the implemen-  tation level of mitigating measures.  In 2024, NTG conducted its second legal compliance risk  assessment across all NTG entities. An updated and automated  questionnaire was distributed to all managing directors. The  results of the 2024 risk assessment informed the mitigation  plan, ensuring a continued focus on high-risk entities and legal  compliance areas.  SPEAK UP!  Another element in NTG's work to prevent, detect and address  allegations or incidents with corruption or bribery NTG has  implemented the Whistleblower System, called SPEAK UP!. The  system is administered by an independent third party to ensure  anonymity. All reports made via NTG's whistleblowing system  are received by the external and independent third-party to  NTG. Upon screening of the report and assessment of who at  NTG should receive the report for further processing, the report  is forwarded in accordance with the Whistleblower policy. All  reports submitted must be investigated. Any investigation must  be finalised by a written report containing a conclusion and/or  recommendation for further action based on the findings of the  report. The report is passed to NTG's audit committee  Training on Code of Conduct, policies, and new legislation  The Code of Conduct is handed out to all employees upon em-  ployment. Furthermore, the code is available on NTG's intranet  as well as NTGâs public website.To ensure that all employees  understand and adhere to our Code of Conduct and other  elements of our Legal Compliance Program, we prioritise online  training. We aim for all employees to complete annual training  on our Code of Conduct, and we report on our progress every  year.  MDR-A, G1-4  NTGâs online compliance training is intended to help employees  recognise and avoid risks in their daily tasks. Employees with  computers access are invited to participate in online training  modules covering NTGâs Code of Conduct, Anti-Corruption Poli-  cy, Foreign Trade Controls Policy, and Competition Laws Policy.  Each module includes an introduction video by the Group  CEO or Group Legal, a training video, and a test. Group Legal  monitors employee participation in the training. New employees  must read NTGâs Code of Conduct and participate in various  training sessions related to our operational systems.  Due to restructuring of the Code of Conduct training, NTG did  not conduct a full training session in 2024 among its employees.  Only newly hired employees during 2024 received information  on NTG's Code of Conduct. This implies that 20.6% of NTG's  employees received information and training in our Code of  Conduct as this equals the percentage of newly hired employees  in 2024. Remaining functions at risk did not receive any training  in 2024 due to restructering of the training programme. We will  resume our training for employees in 2025.  Supplier compliance  Controls are conducted on an ongoing basis on groups of sup-  pliersâ compliance with sanctions and embargoes, using various  compliance tools and automatic screening in the transport man-  agement systems. Further, compliance checks are performed on  groups of new suppliers upon completion of new contracts and  engagement.  Confirmed incidents of corruption or bribery  In the reporting period, NTG was not involved in any breaches,  cases or convictions nor fined in relation to violation of anti-  corruption and anti-bribery laws.  MDR-T  Tracking effectiveness of policies and actions  through targets  To be able to continuously prevent and detect corruption and  bribery, NTG has set various targets to ensure progress to its  responsible business practises that also are presented in the  table on page 107.  One target relates to our yearly compliance training of employees  in our Code of Conduct. This includes both functions at risk in  NTG as well as all other employees with daily access to a com-  puter, as the compliance training is conducted online.  A second target is NTGâs commitment to perform yearly compli-  ance audits and spot checks of suppliers through remote audits,  questionnaires, and checklists. As previously mentioned, we  perform an ongoing control of groups of suppliers for compliance  with sanctions and embargoes as well as compliance checks of  groups of new suppliers. During 2025, NTG intends to introduce  a spot check control of selected supplier for compliance of  NTGâs Code of Conduct for Suppliers.  A third target that will progress during 2025 is a follow-up  session on NTGâs internal risk assessment. Randomly selected  NTG entities will have a follow-up session to monitor the effec-  tiveness of any mitigating measures implemented as a result of  the risk assessment process and under NTGâs Legal Compliance  Program.  GOV-4  Statement on due diligence  Disclosure related to:  Core elements of due diligence  Disclosure requirement  Page  People  Environment  ESRS 2 GOV-2  48  ââESRS 2 GOV-3  48  ââa) Embedding due diligence  ESRS 2 SBM-3  55  ââin governance, strategy and  ESRS 2 SBM-3-E1  65  âbusiness model  ESRS 2 SBM-3-S1  92  âESRS 2 SBM-3-S2  100  âESRS 2 SBM-3-G1  109  ââESRS 2 GOV-2  48  ââESRS 2 SBM-2  53  ââESRS 2 IRO-1  57  ââb) Engaging with affected  ESRS 2 MDR-P/E1-2  66  âstakeholders in all key steps  S1-2  93  âof the due diligence  S2-1  101  âS2-2  103  âS1-2  93  âESRS 2 MDR-P/G1-1  109  ââAdditional information to the Sustainability Statement  Disclosure related to:  Core elements of due diligence  Disclosure requirement  Page  People  Environment  ESRS 2 IRO-1  57  ââESRS 2 SBM-3-E1  64  âc) Identifying and assessing  ESRS 2 SBM-3-S1  91  âadverse impacts  ESRS 2 SBM-3-S2  100  âESRS 2 SBM-3-G1  109  ââE1-1  61  âESRS MDR-A/E1-3  67  âd) Taking actions to address  ESRS MDR-A/S1-4  104  âthose adverse impacts  ESRS MDR-A/S2-4  104  âG1-1  109  ââG1-3  110  ââESRS MDR-M/E1-5  73  e) Tracking the effectiveness  G1-4  110  ââof these efforts and  MDR-T/E1-4  68  âcommunicating  MDR-T/S1-5  93  âESRS2 IRO-2  List of datapoints that derive from  other EU legislation  Disclosure requirement ESRS 2 IRO-2 paragraph 56 & ESRS 2 Appendix B  Disclosure Requirement and  SFDR  Pillar 3  EU Climate Law  Page  related datapoint  reference  reference  Benchmark Regulation reference  reference  Comment  reference  General  ESRS 2 GOV-1 Board's gender diversity paragraph 21 (d)  Indicator number 13 of Table #1 of  Commission Delegated Regulation (EU)  107  Annex 1  2020/1816 (27), Annex II  ESRS 2 GOV-1 Percentage of board members who are  Delegated Regulation (EU) 2020/1816,  36  independent paragraph 21 (e)  Annex II  ESRS 2 GOV-4 Statement on due diligence paragraph 30  Indicator number 10 Table #3 of Annex 1  113  ESRS 2 SBM-1 Involvement in activities related to fossil fuel  Indicators number 4 Table #1 of Annex 1  Article 449a Regulation (EU) No  Delegated Regulation (EU) 2020/1816,  Not relevant  activities paragraph 40 (d) i  575/2013; Commission Implementing  Annex II  Regulation (EU) 2022/2453 (28) Table 1:  Qualitative information on Environmental  risk and Table 2: Qualitative information  on Social risk  ESRS 2 SBM-1 Involvement in activities related to chemical  Indicator number 9 Table #2 of Annex 1  Delegated Regulation (EU) 2020/1816,  Not relevant  production paragraph 40 (d) ii  Annex II  ESRS 2 SBM-1 Involvement in activities related to  Indicator number 14 Table #1 of Annex 1  Delegated Regulation (EU) 2020/1818  Not relevant  controversial weapons paragraph 40 (d) iii  14, Article 12(1) Delegated Regulation  (EU) 2020/1816, Annex II  ESRS 2 SBM-1 Involvement in activities related to cultivation  Delegated Regulation (EU) 2020/1818,  Not relevant  and production of tobacco paragraph 40 (d) iv  Article 12(1) Delegated Regulation (EU)  2020/1816, Annex II  Disclosure Requirement and  SFDR  Pillar 3  EU Climate Law  Page  related datapoint  reference  reference  Benchmark Regulation reference  reference  Comment  reference  Environment  ESRS E1-1 Transition plan to reach climate neutrality by  Regulation (EU) 2021/1119, Article 2(1)  61  2050 paragraph 14  ESRS E1-1 Undertakings excluded from Paris-aligned  Article 449a Regulation (EU) No  Delegated Regulation (EU) 2020/1818,  61  Benchmarks paragraph 16 (g)  575/2013; Commission Implementing  Article 12.1 (d) to (g), and Article 12.2  Regulation (EU) 2022/2453 Template 1:  Banking book Climate Change transition  risk: Credit quality of exposures by sector,  emissions and residual maturity  ESRS E1-4 GHG emission reduction targets paragraph 34  Indicator number 4 Table #2 of Annex 1  Article 449a Regulation (EU) No  Delegated Regulation (EU) 2020/1818,  68  575/2013; Commission Implementing  Article 6  Regulation (EU) 2022/2453 Template 3:  Banking book â Climate change transition  risk: alignment metrics  ESRS E1-5 Energy consumption from fossil sources  Indicator number 5 Table #1 and Indicator  73  disaggregated by sources (only high climate impact sectors)  n. 5 Table #2 of Annex 1  paragraph 38  ESRS E1-5 Energy consumption and mix paragraph 37  Indicator number 5 Table #1 of Annex 1  73  ESRS E1-5 Energy intensity associated with activities in high  Indicator number 6 Table #1 of Annex 1  73  climate impact sectors paragraphs 40 to 43  ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions  Indicators number 1 and 2 Table #1 of  Article 449a; Regulation (EU) No  Delegated Regulation (EU) 2020/1818,  70  paragraph 44  Annex 1  575/2013; Commission Implementing  Article 5(1), 6 and 8(1)  Regulation (EU) 2022/2453 Template 1:  Banking book - Climate change transition  risk: Credit quality of exposures by sector,  emissions and residual maturity  ESRS E1-6 Gross GHG emissions intensity paragraphs 53  Indicators number 3 Table #1 of Annex 1  Article 449a Regulation (EU) No  Delegated Regulation (EU) 2020/1818,  69  to 55  575/2013; Commission Implementing  Article 8(1)  Regulation (EU) 2022/2453 Template 3:  Banking book - Climate change transition  risk: alignment metrics  ESRS E1-7 GHG removals and carbon credits paragraph 56  Regulation (EU) 2021/1119, Article 2(1)  Not relevant  ESRS E1-9 Exposure of the benchmark portfolio to climate-  Delegated Regulation (EU) 2020/1818,  Not material  related physical risks paragraph 66  Annex II Delegated Regulation (EU)  2020/1816, Annex II  Disclosure Requirement and  SFDR  Pillar 3  EU Climate Law  Page  related datapoint  reference  reference  Benchmark Regulation reference  reference  Comment  reference  ESRS E1-9 Disaggregation of monetary amounts by acute  Article 449a Regulation (EU) No  Not material  and chronic physical risk paragraph 66 (a) ESRS E1-9  575/2013; Commission Implementing  Location of significant assets at material physical risk  Regulation (EU) 2022/2453 paragraphs  paragraph 66 (c).  46 and 47; Template 5: Banking book -  Climate change physical risk: Exposures  subject to physical risk.  ESRS E1-9 Breakdown of the carrying value of its real estate  Article 449a Regulation (EU) No  Not material  assets by energy- efficiency classes paragraph 67 (c).  575/2013; Commission Implementing  Regulation (EU) 2022/2453 paragraph  34; Template 2: Banking book  -Climate change transition risk: Loans  collateralised by immovable property -  Energy efficiency of the collateral  ESRS E1-9 Degree of exposure of the portfolio to climate-  Delegated Regulation (EU) 2020/1818,  Not relevant  related opportunities paragraph 69  Annex II  ESRS E2-4 Amount of each pollutant listed in Annex II of the  Indicator number 8 Table #1 of Annex 1  78  EPRTR Regulation (European Pollutant Release and Transfer  Indicator number 2 Table #2 of Annex 1  Register) emitted to air, water and soil, paragraph 28  Indicator number 1 Table #2 of Annex 1  Indicator number 3 Table #2 of Annex 1  ESRS E3-1 Water and marine resources paragraph 9  Indicator number 7 Table #2 of Annex 1  Not material  ESRS E3-1 Dedicated policy paragraph 13  Indicator number 8 Table 2 of Annex 1  Not material  ESRS E3-1 Sustainable oceans and seas paragraph 14  Indicator number 12 Table #2 of Annex 1  Not material  ESRS E3-4 Total water recycled and reused paragraph 28 (c)  Indicator number 6.2 Table #2 of Annex 1  Not material  ESRS E3-4 Total water consumption in m 3 per net revenue  Indicator number 6.1 Table #2 of Annex 1  Not material  on own operations paragraph 29  ESRS 2- IRO 1 - E4 paragraph 16 (a) i  Indicator number 7 Table #1 of Annex 1  Not material  ESRS 2- IRO 1 - E4 paragraph 16 (b)  Indicator number 10 Table #2 of Annex 1  Not material  ESRS 2- IRO 1 - E4 paragraph 16 (c)  Indicator number 14 Table #2 of Annex 1  Not material  ESRS E4-2 Sustainable land / agriculture practices or policies  Indicator number 11 Table #2 of Annex 1  Not material  paragraph 24 (b)  ESRS E4-2 Sustainable oceans / seas practices or policies  Indicator number 12 Table #2 of Annex 1  Not material  paragraph 24 (c)  ESRS E4-2 Policies to address deforestation paragraph 24 (d)  Indicator number 15 Table #2 of Annex 1  Not material  ESRS E5-5 Non-recycled waste paragraph 37 (d)  Indicator number 13 Table #2 of Annex 1  Not material  ESRS E5-5 Hazardous waste and radioactive waste  Indicator number 9 Table #1 of Annex 1  Not material  paragraph 39  Disclosure Requirement and  SFDR  Pillar 3  EU Climate Law  Page  related datapoint  reference  reference  Benchmark Regulation reference  reference  Comment  reference  Social  ESRS 2- SBM3 - S1 Risk of incidents of forced labour  Indicator number 13 Table #3 of Annex I  91  paragraph 14 (f)  ESRS 2- SBM3 - S1 Risk of incidents of child labour  Indicator number 12 Table #3 of Annex I  91  paragraph 14 (g)  ESRS S1-1 Human rights policy commitments paragraph 20  Indicator number 9 Table #3 and Indicator  92  number 11 Table #1 of Annex I  ESRS S1-1 Due diligence policies on issues addressed by the  Delegated Regulation (EU) 2020/1816,  92  fundamental International Labor Organisation Conventions 1  Annex II  to 8, paragraph 21  ESRS S1-1 processes and measures for preventing trafficking  Indicator number 11 Table #3 of Annex I  92  in human beings paragraph 22  ESRS S1-1 workplace accident prevention policy or  Indicator number 1 Table #3 of Annex I  92  management system paragraph 23  ESRS S1-3 grievance/complaints handling mechanisms  Indicator number 5 Table #3 of Annex I  94  paragraph 32 (c)  ESRS S1-14 Number of fatalities and number and rate of  Indicator number 2 Table #3 of Annex I  Delegated Regulation (EU) 2020/1816,  97  work-related accidents paragraph 88 (b) and (c)  Annex II  ESRS S1-14 Number of days lost to injuries, accidents,  Indicator number 3 Table #3 of Annex I  97  fatalities or illness paragraph 88 (e)  ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a)  Indicator number 12 Table #1 of Annex I  Delegated Regulation (EU) 2020/1816,  Not material  Annex II  ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b)  Indicator number 8 Table #3 of Annex I  Not material  ESRS S1-17 Incidents of discrimination paragraph 103 (a)  Indicator number 7 Table #3 of Annex I  99  ESRS S1-17 Non-respect of UNGPs on Business and Human  Indicator number 10 Table #1 and  Delegated Regulation (EU) 2020/1816,  99  Rights and OECD paragraph 104 (a)  Indicator n. 14 Table #3 of Annex I  Annex II Delegated Regulation (EU)  2020/1818 Art 12 (1)  ESRS 2- SBM3 â S2 Significant risk of child labour or forced  Indicators number 12 and n. 13 Table #3  93  labour in the value chain paragraph 11 (b)  of Annex I  ESRS S2-1 Human rights policy commitments paragraph 17  Indicator number 9 Table #3 and Indicator  51  n. 11 Table #1 of Annex 1  ESRS S2-1 Policies related to value chain workers paragraph  Indicator number 11 and n. 4 Table #3 of  101  18  Annex 1  ESRS S2-1 Non-respect of UNGPs on Business and Human  Indicator number 10 Table #1 of Annex 1  Delegated Regulation (EU) 2020/1816,  93  Rights principles and OECD guidelines paragraph 19  Annex II Delegated Regulation (EU)  2020/1818, Art 12 (1)  Disclosure Requirement and  SFDR  Pillar 3  EU Climate Law  Page  related datapoint  reference  reference  Benchmark Regulation reference  reference  Comment  reference  ESRS S2-1 Due diligence policies on issues addressed by the  Delegated Regulation (EU) 2020/1816,  101  fundamental International Labor Organisation Conventions 1  Annex II  to 8, paragraph 19  ESRS S2-4 Human rights issues and incidents connected to  Indicator number 14 Table #3 of Annex 1  102  its upstream and downstream value chain paragraph 36  ESRS S3-1 Human rights policy commitments paragraph 16  Indicator number 9 Table #3 of Annex  Not material  1 and Indicator number 11 Table #1 of  Annex 1  ESRS S3-1 non- respect of UNGPs on Business and Human  Indicator number 10 Table #1 Annex 1  Delegated Regulation (EU) 2020/1816,  Not material  Rights, ILO principles or and OECD guidelines paragraph 17  Annex II Delegated Regulation (EU)  2020/1818, Art 12 (1)  ESRS S3-4 Human rights issues and incidents paragraph 36  Indicator number 14 Table #3 of Annex 1  Not material  ESRS S4-1 Policies related to consumers and end-users  Indicator number 9 Table #3 and Indicator  Not material  paragraph 16  number 11 Table #1 of Annex 1  ESRS S4-1 Non-respect of UNGPs on Business and Human  Indicator number 10 Table #1 of Annex 1  Delegated Regulation (EU) 2020/1816,  Not material  Rights and OECD guidelines paragraph 17  Annex II Delegated Regulation (EU)  2020/1818, Art 12 (1) 31  ESRS S4-4 Human rights issues and incidents paragraph 35  Indicator number 14 Table #3 of Annex 1  Not material  Governance  ESRS G1-1 United Nations Convention against Corruption  Indicator number 15 Table #3 of Annex 1  109  paragraph 10 (b)  ESRS G1-1 Protection of whistle-blowers paragraph 10 (d)  Indicator number 6 Table #3 of Annex 1  110  ESRS G1-4 Fines for violation of anti-corruption and anti-  Indicator number 17 Table #3 of Annex 1  Delegated Regulation (EU) 2020/1816,  110  bribery laws paragraph 24 (a)  Annex II  ESRS G1-4 Standards of anti-corruption and anti-bribery  Indicator number 16 Table #3 of Annex 1  110  paragraph 24 (b)  Transaction costs  Transaction costs relating to the RTC acquisition amount to DKK 1 million. Trans-  actions costs are accounted for in the income statement as special items  </mrv:SustainabilityReport>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx1" id="fact4596" xml:lang="en">EU Taxonomy  The EU Taxonomy classifies which economic activities are environmentally  sustainable. It is key to the EUâs sustainable finance framework, defining criteria  for activities aligned with a net zero goal by 2050 and other environmental aims.  The EU Taxonomy covers six environmental objectives: Climate  change mitigation, climate change adaptation, sustainable use  and protection of water and marine resources, transition to a  circular economy, pollution prevention and control, and protec-  tion and restoration of biodiversity and ecosystems.  As a listed company with more than 500 employees, NTG must  report according to the EU Taxonomy Delegated Acts ((EU)  2020/852 and its delegated acts).  Taxonomy-eligible activities  An economic activity qualifies under the EU Taxonomy if it  matches one of the defined activities related to any of the six en-  vironmental objectives. This means that the activity must corre-  spond to the description provided by the EU Taxonomy. Eligibility  is determined irrespective of the size of the economic activity.  Enabling activities: These are activities that provide products  or services that help other activities to achieve a substantial  contribution to the environmental objectives. For example, an  activity that produces a component that improves the efficiency  of another activity.  Transitional activities: These are activities that do not have a low  carbon alternative but are necessary for the transition to a cli-  mate-neutral economy. They must be consistent with a pathway  to limit the global temperature increase to 1.5 °C above pre-in-  dustrial levels and phase out greenhouse gas emissions.  NTGâs core activity is asset-light freight forwarding. This is not  included in the EU taxonomy of economic activities that contrib-  ute to the environmental objectives, and therefore, NTGâs core  activity is not eligible under the EU Taxonomy. However, NTG has  analysed its operations and identified some sub-activities that are  eligible under the taxonomy, based on the substantial contribu-  tion criteria, their enabling role or transitional nature.  Taxonomy-aligned activities  To determine if an eligible economic activity is aligned with the  EU taxonomy, it must qualify the Technical Screening Criteria in  Annex 1 and 2 to the Climate Delegated Act. The eligible activi-  ties must meet both the Substantial Contribution and the Do No  Significant Harm (âDNSHâ) criteria, and they must comply with  the Minimum Safeguards, which cover social and governance  standards.  Revenue (DKKm)  2024  2023  Eligible, but not aligned  172  153  % of total  1.8%  1.8%  Eligible and aligned  90  176  % of total  1.0%  2.1%  Total  9,352  8,338  Capex (DKKm)  2024  2023  Eligible, but not aligned  35  16  % of total  3.5%  4.2%  Eligible and aligned  16  12  % of total  1.5%  3.3%  Total  1,007  381  Opex (DKKm)  2024  2023  Eligible, but not aligned  28  26  % of total  23.5%  26.1%  Eligible and aligned  32% of total  2.8%  2.2%  Total  117  100  Proportion of EU Taxonomy aligned revenue (turnover)  Substantial contribution criteria (%)  Does no significant harm criteria (Y/N)  Economic activities  DKKm  %Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  (Y/N)  (Y/N)  (Y/N)  (Y/N)  (Y/N)  (Y/N)  (Y/N)  %ETA. Taxonomy-eligible activities  A.1 Environmentally sustainable activities (Taxonomy-aligned)  Collection and transport of non-hazardous waste in source segregated  5.5  57.4  0.6%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.5%  fractions  Installation, maintenance and repair of renewable energy technologies  7.6  32.7  0.3%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY1.6%  ETurnover of environmentally sustainable activities (Taxonomy-aligned) (A.1.)  90.1  1.0%  1.0%  0.0%  0.0%  0.0%  0.0%  0.0%  YYYYYYY2.1%  Of which enabling  32.7  0.3%  0.3%  0.0%  0.0%  0.0%  0.0%  0.0%  YYYYYYY1.6%  EOf which transitional  -0.0%  0.0%  -------0.0%  TA.2. Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  Collection and transport of non-hazardous waste in source segregated  5.5  3.2  0.0%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.0%  fractions  Installation, maintenance and repair of renewable energy technologies  7.6  0.0  0.0%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.0%  Freight transport services by road  6.6  168.5  1.8%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  1.8%  A.2. Taxonomy-eligible but not environmentally sustainable activities  171.8  1.8%  1.8%  0.0%  0.0%  0.0%  0.0%  0.0%  1.8%  (not Taxonomy-aligned activities) (A.2.)  Total (A.1 +A.2)  261.8  2.8%  2.8%  0.0%  0.0%  0.0%  0.0%  0.0%  3.9%  B. Taxonomy-non-eligible activities  Turnover of Taxonomy non-eligible activities (B)  9,090.1 97.2%  Total (A+B)  9,352.0 100.0%  Proportion of EU Taxonomy aligned capex  Substantial contribution criteria (%)  Does no significant harm criteria (Y/N)  Economic activities  DKKm  %Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  %ETA. Taxonomy-eligible activities  A.1 Environmentally sustainable activities (Taxonomy-aligned)  Transport by motorbikes, passenger cars and light commercial vehicles  6.5  14.3  1.4%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY2.9%  TInstallation, maintenance and repair of energy efficiency equipment  7.3  0.2  0.0%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.2%  Installation, maintenance and repair of charging stations for electric vehicles  7.4  0.7  0.1%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.1%  in buildings (and parking spaces attached to buildings)  Installation, maintenance and repair of renewable energy technologies  7.6  0.4  0.0%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.1%  Environmentally sustainable activities (Taxonomy-aligned) (A.1)  15.6  1.5%  1.5%  0.0%  0.0%  0.0%  0.0%  0.0%  YYYYYYY3.3%  Of which Enabling  -0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  -------0.0%  EOf which Transitional  14.3  1.4%  1.4%  YYYYYYY2.9%  TA.2. Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  Transport by motorbikes, passenger cars and light commercial vehicles  6.5  6.1  0.6%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  1.0%  Freight transport services by road  6.6  29.1  2.9%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  3.2%  A.2 Taxonomy-eligible but not environmentally sustainable activities  35.2  3.5%  3.5%  0.0%  0.0%  0.0%  0.0%  0.0%  4.2%  (not Taxonomy-aligned activities) (A.2)  Total (A.1 +A.2)  50.7  5.0%  5.0%  0.0%  0.0%  0.0%  0.0%  0.0%  7.4%  B. Taxonomy-non-eligible activities  Capex of Taxonomy non-eligible activities (B)  956.3  95.0%  Total (A+B)  1,007.0 100.0%  Proportion of EU Taxonomy â aligned opex  Substantial contribution criteria (%)  Does no significant harm criteria (Y/N)  Economic activities  DKKm  %Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  %ETA. Taxonomy-eligible activities  A.1 Environmentally sustainable activities (Taxonomy-aligned)  Transport by motorbikes, passenger cars and light commercial vehicles  6.5  3.2  2.7%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY2.2%  TInstallation, maintenance and repair of energy efficiency equipment  7.3  0.0  0.0%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.0%  Installation, maintenance and repair of charging stations for electric vehicles  7.4  0.0  0.0%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.0%  in buildings (and parking spaces attached to buildings)  Installation, maintenance and repair of renewable energy technologies  7.6  0.0  0.0%  YN/EL  N/EL  N/EL  N/EL  N/EL  YYYYYYY0.0%  Environmentally sustainable activities (Taxonomy-aligned) (A.1)  3.2  2.8%  2.8%  0.0%  0.0%  0.0%  0.0%  0.0%  YYYYYYY2.2%  Of which enabling  -0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  -------0.0%  EOf which transitional  3.2  2.7%  2.7%  YYYYYYY2.2%  TA.2. Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  Transport by motorbikes, passenger cars and light commercial vehicles  6.5  2.9  2.5%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  3.9%  Freight transport services by road  6.6  24.5  21.0%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  22.3%  A.2 Taxonomy-eligible but not environmentally sustainable activities  27.5  23.5%  23.5%  0.0%  0.0%  0.0%  0.0%  0.0%  26.1%  (not Taxonomy-aligned activities) (A.2)  Total (A.1 +A.2)  30.7  26.3%  26.3%  0.0%  0.0%  0.0%  0.0%  0.0%  28.4%  B. Taxonomy-non-eligible activities  Opex of Taxonomy non-eligible activities (B)  86.2  73.7%  Total (A+B)  117.0 100.0%  Contextual information â Revenue (turnover)  (DKKm)  % of total  Revenue (turnover) KPI  2024  2023  2024  2023  6.6  Freight transport services by road  168.5  150.2  1.8%  1.8%  5.5  Collection and transport of non-hazardous waste in source segregated fractions  3.2  2.4  0.0%  0.0%  7.6  Installation, maintenance and repair of renewable energy technologies  0.0  0.0  0.0%  0.0%  Eligible, but not aligned activities  171.7  152.6  1.8%  1.8%  5.5  Collection and transport of non-hazardous waste in source segregated fractions  57.4  41.5  0.6%  0.5%  7.6  Installation, maintenance and repair of renewable energy technologies  32.7  134.2  0.3%  1.6%  Eligible and aligned activities  90.1  175.7  1.0%  2.1%  Non-eligible activities  9,090.1  8,010.0  97.2%  96.1%  Total revenue (turnover) of the Group (eligible and non-eligible)  9,352.0  8,338.3  100.0%  100.0%  Revenue (turnover)  The total revenue of NTG increased from DKK 8,338  million in 2023 to DKK 9,352 million in 2024, whereas  the revenue from eligible and aligned activities declined.  The decline was caused by less revenue from projects  involving subsea power cables for wind farms.  Revenue from eligible, but not aligned freight  transportation services by road, relating to operation of  own trucks, increased compared to last year due to the  acquisition of Schmalz+Schön, offset by discontinuation  of trucking activity in a NTG entity.  Contextual information â Capex  (DKKm)  % of total  Capex KPI  2024  2023  2024  2023  6.5  Transport by motorbikes, passenger cars and light commercial vehicles  6.1  3.6  0.6%  1.0%  6.6  Freight transport services by road  29.1  12.3  2.9%  3.2%  Eligible, but not aligned activities  35.2  16.0  3.5%  4.2%  6.5  Transport by motorbikes, passenger cars and light commercial vehicles  14.3  10.9  1.4%  2.9%  7.3  Installation, maintenance and repair of energy efficiency equipment  0.2  0.9  0.0%  0.2%  7.4  Installation, maintenance and repair of charging stations for electric vehicles in  0.7  0.3  0.1%  0.1%  buildings (and parking spaces attached to buildings)  7.6  Installation, maintenance and repair of renewable energy technologies  0.4  0.2  0.0%  0.1%  Eligible and aligned activities  15.6  12.4  1.5%  3.3%  Non-eligible activities  956.3  352.7  95.0%  92.6%  Total capex of the Group (eligible and non-eligible)  1,007.0  381.0  100.0%  100.0%  Capex  In 2024, the ratio of capex for eligible, but not aligned,  activities decreaed compared to 2023, despite higher  capex for replacement of trucks. This was driven by a  higher total capex (denominator) in 2024 than in 2023  as a consequence of M&A activity.  The ratio of capex for eligible and aligned activities  decreased compared to 2023. This was driven by a  higher total capex (denominator) in 2024 than in 2023  as a consequence of M&A activity.  Contextual information - Opex  (DKKm)  % of total  Opex KPI  2024  2023  2024  2023  6.5  Transport by motorbikes, passenger cars and light commercial vehicles  2.9  3.9  2.5%  3.9%  6.6  Freight transport services by road  24.5  22.2  21.0%  22.3%  Eligible, but not aligned activities  27.5  26.0  23.5%  26.1%  6.5  Transport by motorbikes, passenger cars and light commercial vehicles  3.2  2.2  2.7%  2.2%  7.3  Installation, maintenance and repair of energy efficiency equipment  0.0  0.0  0.0%  0.0%  7.4  Installation, maintenance and repair of charging stations for electric vehicles in  0.0  0.0  0.0%  0.0%  buildings (and parking spaces attached to buildings)  7.6  Installation, maintenance and repair of renewable energy technologies  0.0  0.0  0.0%  0.0%  Eligible and aligned activities  3.2  2.2  2.8%  2.2%  Non-eligible activities  86.2  71.4  73.7%  71.6%  Total opex of the Group (eligible and non-eligible)  117.0  99.6  100.0%  100.0%  Opex  In 2024, the opex from eligible but not aligned activities  increased slightly due to a higher number of own trucks  driven by the acquisition of Schmalz+Schön.  In 2024, the ratio of Opex from eligible and aligned  activities increased. This was driven by a higher  proportion of company cars being electrical and plugin  hybrid electrical vehicles, in accordance with NTGs  Company car policy.  EU Taxonomy  Accounting policy  Identification of taxonomy-eligible activities  Although NTGâs main activity as freight forwarders is  not covered by the taxonomy, we have identified other  economic activities which are considered as eligible as  they contribute to the climate objectives based on their  own performance, by provision of their products or ser-  vices or by supporting the transition to a climate-neutral  economy. The activities are presented in the adjacent  table.  From eligible to aligned  For each of the identified activities, we determined reve-  nue, operating expenses (opex) and capital expenditures  (capex) related to eligible and aligned activities (see  Accounting Policy for EU Taxonomy KPIs below).  Technical Screening Criteria  In determining the aligned portion of revenue, opex and  capex of the eligible activities, we have, for each activity,  assessed the Technical Screening Criteria (Substantial  Contribution and DNSH).  In relation to DNSH, we have assessed whether it com-  plies with the DNSH criteria listed in Annexes to the Cli-  mate Delegated Acts. We have assessed each individual  DNSH criteria per activity and only included activities  where we assess they comply with the DNSH criteria.  The assessment is based on a combination of desktop  research, judgment and input from our subsidiaries on  the activities performed. See the table on the following  page for an elaboration of the Technical Screening  Criteria assessment.  Minimum Safeguards  Furthermore, we have assessed at an aggregated level,  whether the activities comply with the Minimum Safe-  guards. This requires companies to ensure that these  Minimum Safeguards are supported by procedures that  comply with the OECD Guidelines for Multinational  Enterprises and the UN Guiding Principles on Business  and Human Rights. These safeguards also include the  principles and rights set out in the eight fundamental  conventions defined in the Declaration of the Interna-  tional Labour Organisation on Fundamental Principles  and Rights at Work and the International Bill of Human  Rights.  NTG has adopted several Codes of Conduct, a Legal  Compliance Programme as well as ESG, diversity and  Whistleblower policies. We have addressed relevant  actual and potential adverse impacts related to human  rights and other sustainability risks directly linked to  our own operations and services, supply chains, and  other business relationships. These business standards  are based on thorough due diligence and a risk-based  process, identifying and assessing relevant business  processes and functions, and taking appropriate action  to remediate actual and potential adverse impacts iden-  tified at the time of the assessment.  NTG has issued a number of Codes of Conduct and poli-  cies - all of which are available on our website â that em-  bed responsible business conduct and articulate NTGâs  commitment to principles and standards contained in the  Do No Significant Harm criteria of the Minimum Safe-  guards. We therefore consider that the aligned economic  activities comply with the Minimum Safeguards.  Double counting  None of our identified economic activities contribute to  multiple objectives, as they all contribute to the climate  change mitigation objective. None of the income or  costs are included more than once in the numerator  across the revenue, opex and capex KPI as there are no  overlaps in the activities and revenue/expenses related  to them.  Nuclear and fossil gas  related activities  Nuclear and fossil gas related activities NTG carries out,  funds or has exposures to:  Nuclear energy related activities  The undertaking carries out, funds or  has exposures to research, development,  demonstration and deployment of innovative  No  electricity generation facilities that produce  energy from nuclear processes with minimal  waste from the fuel cycle.  The undertaking carries out, funds or has  exposures to construction and safe operation of  new nuclear installations to produce electricity or  process heat, including for the purposes of district  No  heating or industrial processes such as hydrogen  production, as well as their safety upgrades, using  best available technologies.  The undertaking carries out, funds or has  exposures to safe operation of existing  nuclear installations that produce electricity or  process heat, including for the  No  purposes of district heating or industrial processes  such as hydrogen production from nuclear energy,  as well as their safety upgrades.  Fossil gas related activities  The undertaking carries out, funds or has  exposures to construction or operation of  No  electricity generation facilities that produce  electricity using fossil gaseous fuels.  The undertaking carries out, funds or has  exposures to construction, refurbishment, and  No  operation of combined heat/cool and power  generation facilities using fossil gaseous fuels.  The undertaking carries out, funds or has  exposures to construction, refurbishment and  No  operation of heat generation facilities that  produce heat/cool using fossil gaseous fuels.  Assessment of eligibility and technical screening criteria  Technical Screening Criteria  Activity  Eligibility  Substantial Contribution  DNSH  5.5 Collection and transport  The eligible activity relates to NTG entities transporting non-hazardous  This activity automatically fulfils the substantial contribution criteria  The activityâs compliance is assessed against the criteria described in the  of non-hazardous waste  waste aimed at preparing for reuse or recycling.  to climate change mitigation and climate adaption.  annex A: Generic criteria for DNSH to climate change adaptation. There is no  fractions for recycling  The eligible revenue related to this activity is identified based on the  apparent physical climate risk for this activity.  name and industry of the transport customer as well as the nature and  It is further confirmed at NTG entity level whether the waste fractions  purpose of the transported materials.  are not mixed with other materials with different properties in storage or  transfer facilities.  6.5 Transport by motorbikes,  The eligible activity relates to our leasing and operation of several  The aligned activity is related to company cars that are powered by  The activityâs compliance is assessed against the criteria described in the  passenger cars and light  company cars that comply with the EU emission standards EURO 5 and 6.  electricity and a combination of electricity and fossil fuels (PHEV)  annex A: Generic criteria for DNSH to climate change adaptation. There is no  commercial vehicles  with emissions below 50g CO2/km. From 1 January 2025, only zero  apparent physical climate risk for this activity.  emission vehicles qualify the Substantial Contribution.  By being standard EU type-approved vehicles, it is assumed that the vehicles  comply with the EU thresholds of reusability, recyclability and pollution.  6.6 Freight transport services  The eligible activity relates to NTG entities leasing and operation of  To be aligned, the vehicles are required to have a zero-tailpipe  Not relevant, as the substantial contribution criteria is not qualified.  by road  vehicles falling under the scope of the EU emission standards EURO 6  emission while in operation. None of the eligible vehicles have zero  and performing dedicated freight transport services for customers.  tailpipe emissions.  7.3 Installation, maintenance  The eligible activity relates to our leasing and operation of buildings  To be aligned the activities must comply with minimum requirements  The activityâs compliance is assessed against the criteria described in the  and repair of energy efficiency  and renovation measures related to installation, maintenance or repair  set for individual components and systems and must relate to one of  annex A: Generic criteria for DNSH to climate change adaptation (physical  equipment in buildings  of energy efficiency equipment.  the measures listed under the Substantial Contribution Criteria (a-f).  climate risks), and the Annex C: Generic criteria for DNSH to pollution  prevention and control regarding use and presence of chemicals. It is  assumed that the manufacturers of the equipment comply with applicable  legislation. Further, it is assessed if the building in question is not dedicated  to extraction, storage, transport or manufacture of fossil fuels.  7.4 Installation, maintenance  The eligible activity relates to installation and maintenance of charging  This activity automatically fulfils the Substantial Contribution Criteria  The activityâs compliance is assessed against the criteria described in the  and repair of charging stations  stations for electric vehicles on some of our premises.  to climate change mitigation.  annex A: Generic criteria for DNSH to climate change adaptation (physical  for electric vehicles  climate risks). There is no apparent physical climate risk for this activity.  7.6 Installation, maintenance  The eligible activity relates to NTG entities involved in transports  To be aligned the activity must relate to one of the renewable energy  The activityâs compliance is assessed against the criteria described in the  and repair of renewable  of renewable energy technologies to an installation site, or where  measures listed under the substantial contribution criteria (a-h).  annex A: Generic criteria for DNSH to climate change adaptation (physical  energy technologies, on-site  NTG installs, maintain and repair solar panels and ancillary technical  climate risks). There is no apparent physical climate risk for this activity.  equipment.  Accounting policy for EU Taxonomy KPIs  KPI  Accounting policy  Numerator  Denominator  Revenue (turnover)  The turnover KPI is calculated in accordance with âANNEX I â  Revenue related to taxonomy-eligible (5.5, 6.6 and 7.6) and taxonomy-aligned (5.5 and 7.6)  The denominator for calculating the proportion of taxonomy-  KPIâs of non-financial undertakingsâ.  activities is derived from our transport management and ERP systems at NTG entity, customer level  eligible/-aligned revenue is equivalent to NTG Groupâs total  and asset (vehicle) level.  revenues as stated in note 2.1 of the NTG Annual Report 2024.  Net revenue means the amounts derived from the sale of  The individual NTG entity has contributed to evaluate the economic activity and its compliance  products and the provision of services after deducting sales  with the technical screening criteria.  The revenue is equivalent to the revenue recognised as income  rebates and value added tax and other taxes directly linked to  on the respective customers or assets (vehicles) in 2024.  revenue, consistently with the net revenue reported in the NTG  Annual Report 2024.  Capex  The capex KPI is calculated in accordance with âANNEX I â KPIâs  Capex related to taxonomy-eligible (6.5, 6.6, 7.3, 7.4 and 7.6) and taxonomy-aligned (6.5, 7.3, 7.4  The denominator comprises all additions to intangible and  of non-financial undertakingsâ.  and 7.6) activities are included in the numerator.  tangible assets in accordance with notes 5.1-5.3 of the NTG  Capex reported in the numerator is all related to individual investments and is not part of a larger  Annual Report 2024 (incl. business combinations and IFRS 16  Capex means additions to intangible and tangible fixed assets,  capex plan. Capex specifically included relates to right of use asset additions related to company  right of use assets).  including additions from business combinations, consistent  cars and trucks as well as installation of solar panels, energy efficiency equipment and electric  with the accounting principles of the NTG Annual Report 2024  vehicle charging stations.  (notes 5.1-5.3). Capex includes additions of right of use assets, in  accordance with IFRS 16.  Opex  The opex KPI is calculated in accordance with âANNEX I â KPIâs  Opex related to taxonomy-eligible (6.5, 6.6, 7.3, 7.4 and 7.6) and taxonomy-aligned (6.5, 7.3, 7.4  Opex included in the denominator (and numerator) is limited to  of non-financial undertakingsâ.  and 7.6) activities are included in the numerator.  direct non-capitalised costs that relate to building renovation  Opex reported in the numerator is related to individual expenses and is not part of a larger capex  measures, short-term leases, maintenance and repair, and other  Opex means expenditures reported as part of direct costs or  plan. Opex specifically included relates to operation and maintenance costs of company cars,  direct expenditures relating to the day-to-day servicing of assets  other external expenses in the income statement of NTG Group,  trucks, energy efficiency equipment and solar panels.  of property, plant and equipment. Opex groups included are  in accordance with the accounting principles of the NTG Annual  warehouse, facility, car, truck, and trailer expenses.  Report 2024.  </mrv:DescriptionofTheTaxonomyRegulation>
<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx43" id="fact1000" xml:lang="en">Statement of the Board of Directors  and the Executive Board  The Board of Directors and Executive Board have considered  and adopted the Annual Report of NTG Nordic Transport Group  A/S for the financial year 1 January - 31 December 2024.  The Consolidated Financial Statements have been prepared in  accordance with International Financial Reporting Standards  as adopted by the EU and further requirements in the Danish  Financial Statements Act, and the Parent Company Financial  Statements have been prepared in accordance with the Danish  Financial Statements Act. Managementâs Review has been pre-  pared in accordance with the Danish Financial Statements Act.  In our opinion, the Consolidated Financial Statements and the  Parent Company Financial Statements give a true and fair view  of the financial position at 31 December 2024 of the Group  and the Parent Company and of the results of the Group and  Parent Company operations and consolidated cash flows for the  financial year 1 January - 31 December 2024.  In our opinion, Managementâs Review includes a true and fair  account of the development in the operations and financial  circumstances of the Group and the Parent Company, of the  results for the year and of the financial position of the Group  and the Parent Company as well as a description of the most  significant risks and elements of uncertainty facing the Group  and the Parent Company.  Additionally, the Sustainability statement, which is part of  Management review, has been prepared, in all material respects,  in accordance with paragraph 99a of the Danish Financial  Statements Act. This includes compliance with the European  Sustainability Reporting Standards (ESRS) including that the  process undertaken by Management to identify the reported  information (the âProcessâ) is in accordance with the descrip-  tion set out in the subsection "Description of the processes to  identify and assess material impacts, risks and opportunities" in  the "General" section of the Sustainability statement. Fur-  thermore, disclosures in the subsection "EU taxonomy" in the  "Environment" section of the Sustainability statement are, in all  material respects, in accordance with Article 8 of EU Regulation  2020/852 (the âTaxonomy Regulationâ).  The year 2024 marks the initial implementation of paragraph  99a of the Danish Financial Statements Act concerning compli-  ance with the ESRS. As such, more clear guidance and practice  are anticipated in various areas, which are expected to be issued  in the coming years. Furthermore, the sustainability state-  ment includes forward-looking statements based on disclosed  assumptions about events that may occur in the future and  possible future actions by the Group. Actual outcomes are likely  to be different since anticipated events frequently do not occur  as expected.  In our opinion, the Annual Report of NTG Nordic Transport  Group A/S for the financial year 1 January to 31 December  2024 with the file name NTG-2024-12-31-en.zip is prepared, in  all material respects, in compliance with the ESEF Regulation.  We recommend that the Annual Report be adopted at the  Annual General Meeting.  </sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx43" id="fact1055" xml:lang="en">Hvidovre</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx43" id="fact1056">2025-03-05</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx44" id="fact1653" xml:lang="en">Mathias Jensen-Vinstrup</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx44" id="fact1654" xml:lang="en">Group CEO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx45" id="fact1655" xml:lang="en">Christian D. Jakobsen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx45" id="fact1656" xml:lang="en">Group CFO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx46" id="fact1657" xml:lang="en">Eivind Kolding</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx46" id="fact1658" xml:lang="en">Chairman</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx47" id="fact1659" xml:lang="en">Jørgen Hansen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx48" id="fact1661" xml:lang="en">Finn Skovbo Pedersen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx51" id="fact1664" xml:lang="en">Karen-Marie Katholm</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx47" id="fact1660" xml:lang="en">Deputy chairman</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx49" id="fact1662" xml:lang="en">Carsten Krogsgaard Thomsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx50" id="fact1663" xml:lang="en">Jesper Præstensgaard</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx52" id="fact1665" xml:lang="en">Louise Knauer</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<arr:IndependentAuditorsReportsAudit contextRef="ctx43" id="fact1057" xml:lang="en">Independent Auditorâs Reports  </arr:IndependentAuditorsReportsAudit>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx43" id="fact1058" xml:lang="en">To the shareholders of  NTG Nordic Transport Group A/S  </arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:AuditorsReportOnFinancialStatements contextRef="ctx43" id="fact1060" xml:lang="en">Report on the audit of the Financial Statements  </arr:AuditorsReportOnFinancialStatements>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx43" id="fact1061" xml:lang="en">In our opinion, the Consolidated Financial Statements give a  true and fair view of the Groupâs financial position at 31 Decem-  ber 2024 and of the results of the Groupâs operations and cash  flows for the financial year 1 January to 31 December 2024 in  accordance with IFRS Accounting Standards as adopted by the  EU and further requirements in the Danish Financial Statements  Act.  Moreover, in our opinion, the Parent Company Financial  Statements give a true and fair view of the Parent Companyâs  financial position at 31 December 2024 and of the results of the  Parent Companyâs operations for the financial year 1 January  to 31 December 2024 in accordance with the Danish Financial  Statements Act.  Our opinion is consistent with our Auditorâs Long-form Report  to the Audit Committee and the Board of Directors.  What we have audited  The Consolidated Financial Statements (pp. 119-154) and the  Parent Company Financial Statements (pp. 156-163) of NTG  Nordic Transport Group A/S for the financial year 1 January to  31 December 2024 comprise income statement, balance sheet,  statement of changes in equity and notes, including material  accounting policy information for the Group as well as for the  Parent Company and statement of comprehensive income and  cash flow statement for the Group. Collectively referred to as  the âFinancial Statementsâ.  </arr:OpinionOnAuditedFinancialStatements>
<arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx43" id="fact1088" xml:lang="en">Basis for opinion  We conducted our audit in accordance with International  Standards on Auditing (ISAs) and the additional requirements  applicable in Denmark. Our responsibilities under those stand-  ards and requirements are further described in the Auditorâs  responsibilities for the audit of the Financial Statements section of  our report.  We believe that the audit evidence we have obtained is suffi-  cient and appropriate to provide a basis for our opinion.  Independence  We are independent of the Group in accordance with the Inter-  national Ethics Standards Board for Accountantsâ International  Code of Ethics for Professional Accountants (IESBA Code) and  the additional ethical requirements applicable in Denmark. We  have also fulfilled our other ethical responsibilities in accord-  ance with these requirements and the IESBA Code.  To the best of our knowledge and belief, prohibited non-au-  dit services referred to in Article 5(1) of Regulation (EU) No  537/2014 were not provided.  Appointment  We were first appointed auditors of NTG Nordic Transport  Group A/S on 16 April 2020 for the financial year 2020. We  have been reappointed annually by shareholder resolution for a  total period of uninterrupted engagement of five years including  the financial year 2024.  </arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:KeyAuditMattersAudit contextRef="ctx43" id="fact1117" xml:lang="en">Key audit matters  Key audit matters are those matters that, in our profession-  al judgement, were of most significance in our audit of the  Financial Statements for 2024. These matters were addressed in  the context of our audit of the Financial Statements as a whole,  and in forming our opinion thereon, and we do not provide a  separate opinion on these matters.  Key audit matter  Accrued revenue and accrued cost of services  The Groupâs revenue consists primarily of services, i.e. transportation of  goods between destinations, which by nature is rendered over a period of  time. The determination of timing of revenue recognition is dependent on  the application of the Groupâs accounting policies and terms in customer  contracts.  The process of accruing for services rendered around the balance sheet  date is complex and dependent on IT controls in certain operational IT  systems due to a substantial number of transactions. Moreover, in the Air &  Ocean division, a higher estimation uncertainty exists regarding recognising  revenue in the right period at year end due to the services being rendered  over a lengthier period of time.  We focused on this area because, at year end, accrued revenue and accrued  cost of services involve significant accounting estimates which are complex  by nature and which rely on methods and data applied and assumptions  determined by Management.  Reference is made to notes 2.1 and 2.2 to the Consolidated Financial  Statements, and note 1 of the Parent Company Financial Statements.  Business combinations  During the year, the Group completed four business combinations with a  total purchase price of DKK 502 million, of which the most significant was  the acquisitions of Schmalz+Schön Logistics GmbH Region Stuttgart.  Accounting for business combinations is complex and subject to significant  estimates, including the identification and valuation of assets, liabilities,  and contingent consideration. In order to determine the fair value of  the separately identified assets and liabilities in a business combination,  valuation methodologies are applied which require input based on  assumptions about the future. These assumptions comprise e.g. future cash  flow forecasts based on expected market developments and discount rates.  We focused on this area because of the significance to the Consolidated  Financial Statements, the inherent complexity and high degree of estimation  in the accounting for acquisitions. Our focus of the area was on the  acquisition of Schmalz+Schön Logistics GmbH Region Stuttgart.  Reference is made to note 7.1 to the Consolidated Financial Statements.  How our audit addressed the key audit matter  We performed risk assessment procedures in order to obtain an  understanding of IT systems, business processes and relevant controls  regarding revenue and accrued costs. For the controls, we assessed whether  they were designed and implemented to effectively address the risk of  material misstatement.  Our audit procedures included considering the appropriateness of the  accounting policies for revenue recognition applied by Management and  assessing compliance with IFRS.  For accrued revenue and accrued cost of services, we tested input data over  Managementâs run-off analysis to evaluate the precision in the estimates  made.  We also selected a sample of transactions at year end and traced these  to underlying evidence, including proof of delivery, to determine whether  revenue and the related costs are recognised in the right period.  In addition, we applied data analysis in our testing of revenue transactions  in order to identify and assess transactions outside the ordinary transaction  flow.  Our audit procedures included assessing the appropriateness of the  accounting policies for business combinations applied by Management and  assessing compliance with IFRS.  We performed audit procedures related to the opening balance sheets of  the acquired businesses. Furthermore, we reconciled the purchase price to  the Share Purchase Agreements and to the transferred cash considerations.  We involved our valuation specialist in the assessment of the valuation  methodologies and discount rates applied by Management in their fair  value assessments of the purchase consideration and acquired assets and  liabilities.  Furthermore, we challenged Managementâs significant assumptions used to  determine the fair value of the acquired assets and liabilities in the business  acquisition.  Finally, we assessed the adequacy of disclosures relating to the business  combinations.  </arr:KeyAuditMattersAudit>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx43" id="fact1192" xml:lang="en">Statement on Managementâs Review  Management is responsible for Managementâs Review (pp. 2-118  and p. 155).  Our opinion on the Financial Statements does not cover Man-  agementâs Review, and we do not as part of the audit express any  form of assurance conclusion thereon.  In connection with our audit of the Financial Statements, our  responsibility is to read Managementâs Review and, in doing so,  consider whether Managementâs Review is materially inconsist-  ent with the Financial Statements or our knowledge obtained in  the audit, or otherwise appears to be materially misstated.  Moreover, we considered whether Managementâs Review  includes the disclosures required by the Danish Financial State-  ments Act. This does not include the requirements in paragraph  99 a related to the sustainability statement covered by the sepa-  rate auditorâs limited assurance report hereon.  Based on the work we have performed, in our view, Manage-  mentâs Review is in accordance with the Consolidated Financial  Statements and the Parent Company Financial Statements and  has been prepared in accordance with the requirements of the  Danish Financial Statements Act, except for the requirements in  paragraph 99 a related to the sustainability statement, cf. above.  We did not identify any material misstatement in Managementâs  Review.  </arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx43" id="fact1235" xml:lang="en">Auditorâs responsibilities for the audit of the  Financial Statements  Our objectives are to obtain reasonable assurance about whether  the Financial Statements as a whole are free from material  misstatement, whether due to fraud or error, and to issue an audi-  torâs report that includes our opinion. Reasonable assurance is a  high level of assurance, but is not a guarantee that an audit con-  ducted in accordance with ISAs and the additional requirements  applicable in Denmark will always detect a material misstatement  when it exists. Misstatements can arise from fraud or error and  are considered material if, individually or in the aggregate, they  could reasonably be expected to influence the economic deci-  sions of users taken on the basis of these Financial Statements.  As part of an audit in accordance with ISAs and the additional  requirements applicable in Denmark, we exercise professional  judgement and maintain professional scepticism throughout the  audit. We also:  · Identify and assess the risks of material misstatement of the  Financial Statements, whether due to fraud or error, design  and perform audit procedures responsive to those risks, and  obtain audit evidence that is sufficient and appropriate to  provide a basis for our opinion. The risk of not detecting a ma-  terial misstatement resulting from fraud is higher than for one  resulting from error, as fraud may involve collusion, forgery,  intentional omissions, misrepresentations, or the override of  internal control.  · Obtain an understanding of internal control relevant to the  audit in order to design audit procedures that are appropriate  in the circumstances, but not for the purpose of expressing  an opinion on the effectiveness of the Groupâs and the Parent  Companyâs internal control.  · Evaluate the appropriateness of accounting policies used and  the reasonableness of accounting estimates and related disclo-  sures made by Management.  · Conclude on the appropriateness of Managementâs use of  the going concern basis of accounting and based on the audit  evidence obtained, whether a material uncertainty exists  related to events or conditions that may cast significant doubt  on the Groupâs and the Parent Companyâs ability to continue  as a going concern. If we conclude that a material uncertain-  ty exists, we are required to draw attention in our auditorâs  report to the related disclosures in the Financial Statements  or, if such disclosures are inadequate, to modify our opinion.  Our conclusions are based on the audit evidence obtained up  to the date of our auditorâs report. However, future events or  conditions may cause the Group or the Parent Company to  cease to continue as a going concern.  · Evaluate the overall presentation, structure and content of the  Financial Statements, including the disclosures, and whether  the Financial Statements represent the underlying transac-  tions and events in a manner that gives a true and fair view.  We communicate with those charged with governance regarding,  among other matters, the planned scope and timing of the audit  and significant audit findings, including any significant deficien-  cies in internal control that we identify during our audit.  We also provide those charged with governance with a statement  that we have complied with relevant ethical requirements regard-  ing independence, and to communicate with them all relation-  ships and other matters that may reasonably be thought to bear  on our independence and, where applicable, actions taken to  eliminate threats or safeguards applied.  From the matters communicated with those charged with  governance, we determine those matters that were of most sig-  nificance in the audit of the Financial Statements of the current  period and are therefore the key audit matters. We describe  these matters in our auditorâs report unless law or regulation  precludes public disclosure about the matter.  </arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx43" id="fact1216" xml:lang="en">Managementâs responsibilities for the  Financial Statements  Management is responsible for the preparation of consolidated  financial statements that give a true and fair view in accordance  with IFRS Accounting Standards as adopted by the EU and  further requirements in the Danish Financial Statements Act and  for the preparation of parent company financial statements that  give a true and fair view in accordance with the Danish Financial  Statements Act, and for such internal control as Management  determines is necessary to enable the preparation of financial  statements that are free from material misstatement, whether  due to fraud or error.  In preparing the Financial Statements, Management is responsi-  ble for assessing the Groupâs and the Parent Companyâs ability  to continue as a going concern, disclosing, as applicable, matters  related to going concern and using the going concern basis of  accounting unless Management either intends to liquidate the  Group or the Parent Company or to cease operations, or has no  realistic alternative but to do so.  </arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx1" id="fact8492" xml:lang="en">· Plan and perform the group audit to obtain sufficient appro-  priate audit evidence regarding the financial information of  the entities or business units within the group as a basis for  forming an opinion on the Consolidated Financial Statements.  We are responsible for the direction, supervision and review  of the audit work performed for purposes of the group audit.  We remain solely responsible for our audit opinion.  </arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:SignatureOfAuditorsPlace contextRef="ctx43" id="fact1384" xml:lang="en">Hellerup</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx43" id="fact1385">2025-03-05</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx58" id="fact1690" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:NameOfAuditFirm contextRef="ctx57" id="fact1678" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx58" id="fact1689">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx57" id="fact1680">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx43" id="fact1312" xml:lang="en">Report on compliance with the ESEF Regulation  As part of our audit of the Financial Statements we performed  procedures to express an opinion on whether the annual report  of NTG Nordic Transport Group A/S for the financial year 1  January to 31 December 2024 with the filename NTG-2024-12-  31-en.zip is prepared, in all material respects, in compliance with  the Commission Delegated Regulation (EU) 2019/815 on the Eu-  ropean Single Electronic Format (ESEF Regulation) which includes  requirements related to the preparation of the annual report in  XHTML format and iXBRL tagging of the Consolidated Financial  Statements including notes.  Management is responsible for preparing an annual report that  complies with the ESEF Regulation. This responsibility includes:  · The preparing of the annual report in XHTML format;  · The selection and application of appropriate iXBRL tags,  including extensions to the ESEF taxonomy and the anchoring  thereof to elements in the taxonomy, for all financial informa-  tion required to be tagged using judgement where necessary;  · Ensuring consistency between iXBRL tagged data and the  Consolidated Financial Statements presented in human-read-  able format; and  · For such internal control as Management determines nec-  essary to enable the preparation of an annual report that is  compliant with the ESEF Regulation.  Our responsibility is to obtain reasonable assurance on whether  the annual report is prepared, in all material respects, in compli-  ance with the ESEF Regulation based on the evidence we have  obtained, and to issue a report that includes our opinion. The  nature, timing and extent of procedures selected depend on the  auditorâs judgement, including the assessment of the risks of ma-  terial departures from the requirements set out in the ESEF Reg-  ulation, whether due to fraud or error. The procedures include:  · Testing whether the annual report is prepared in XHTML  format;  · Obtaining an understanding of the companyâs iXBRL tagging  process and of internal control over the tagging process;  · Evaluating the completeness of the iXBRL tagging of the Con-  solidated Financial Statements including notes;  · Evaluating the appropriateness of the companyâs use of iXBRL  elements selected from the ESEF taxonomy and the creation  of extension elements where no suitable element in the ESEF  taxonomy has been identified;  · Evaluating the use of anchoring of extension elements to  elements in the ESEF taxonomy; and  · Reconciling the iXBRL tagged data with the audited Consoli-  dated Financial Statements.  In our opinion, the annual report of NTG Nordic Transport Group  A/S for the financial year 1 January to 31 December 2024 with  the file name NTG-2024-12-31-en.zip is prepared, in all material  respects, in compliance with the ESEF Regulation.  </arr:AuditorsReportOnXbrlTagging>
<cmn:NameAndSurnameOfAuditor contextRef="ctx57" id="fact1681" xml:lang="en">Tue Stensgård Sørensen</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx57" id="fact1682" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx57" id="fact1684" xml:lang="en">mne32200</cmn:IdentificationNumberOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx58" id="fact1685" xml:lang="en">Jacob Brinch</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx58" id="fact1686" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx58" id="fact1688" xml:lang="en">mne35447</cmn:IdentificationNumberOfAuditor>
<arr:AuditorsReportOnSubstainabilityReport contextRef="ctx43" id="fact1386" xml:lang="en">Independent auditorâs limited assurance report on  the Sustainability Statement  To the Stakeholders of  NTG Nordic Transport Group A/S  Limited assurance conclusion  We have conducted a limited assurance engagement on the sus-  tainability statement of NTG Nordic Transport Group A/S (the  âGroupâ) included in the Management review (the âSustainabil-  ity Statementâ), pages 44-118, for the financial year 1 January  â 31 December 2024.  Based on the procedures we have performed and the evidence  we have obtained, nothing has come to our attention that  causes us to believe that the Sustainability Statement is not  prepared, in all material respects, in accordance with the Danish  Financial Statements Act paragraph 99 a, including:  · compliance with the European Sustainability Reporting  Standards (ESRS), including that the process carried out by  the management to identify the information reported in the  Sustainability Statement (the âProcessâ) is in accordance with  the description set out in the section titled âDescription of the  processes to identify and assess material impacts, risks and  opportunitiesâ, page 57; and  · compliance of the disclosures in the section âEU taxonomyâ,  pages 79-88, with Article 8 of EU Regulation 2020/852 (the  âTaxonomy Regulationâ).  Basis for conclusion  We conducted our limited assurance engagement in accordance  with International Standard on Assurance Engagements (ISAE)  3000 (Revised), Assurance engagements other than audits or  reviews of historical financial information (âISAE 3000 (Revised)â)  and the additional requirements applicable in Denmark.  The procedures in a limited assurance engagement vary in na-  ture and timing from, and are less in extent than for, a reasona-  ble assurance engagement. Consequently, the level of assurance  obtained in a limited assurance engagement is substantially  lower than the assurance that would have been obtained had a  reasonable assurance engagement been performed.  We believe that the evidence we have obtained is sufficient and  appropriate to provide a basis for our conclusion. Our responsi-  bilities under this standard are further described in the Auditorâs  responsibilities for the assurance engagement section of our  report.  Our independence and quality management  We are independent of the Group in accordance with the Inter-  national Ethics Standards Board for Accountantsâ International  Code of Ethics for Professional Accountants (IESBA Code) and  the additional ethical requirements applicable in Denmark. We  have also fulfilled our other ethical responsibilities in accord-  ance with these requirements and the IESBA Code.  Our firm applies International Standard on Quality Management  1, which requires the firm to design, implement and operate a  system of quality management including policies or procedures  regarding compliance with ethical requirements, professional  standards and applicable legal and regulatory requirements.ê¢ Â Managementâs responsibilities for  the Sustainability Statement  Management is responsible for designing and implementing a  process to identify the information reported in the Sustainabil-  ity Statement in accordance with the ESRS and for disclosing  this Process as included in the section titled âDescription of  the processes to identify and assess material impacts, risks and  opportunitiesâ, page 57. This responsibility includes:  · understanding the context in which the Groupâs activities and  business relationships take place and developing an under-  standing of its affected stakeholders;  · the identification of the actual and potential impacts (both  negative and positive) related to sustainability matters, as well  as risks and opportunities that affect, or could reasonably be  expected to affect, the Groupâs financial position, financial  performance, cash flows, access to finance or cost of capital  over the short-, medium-, or long-term;  · the assessment of the materiality of the identified impacts,  risks and opportunities related to sustainability matters by  selecting and applying appropriate thresholds; and  · making assumptions that are reasonable in the circumstances.  Management is further responsible for the preparation of the  Sustainability Statement, which includes the information iden-  tified by the Process, in accordance with the Danish Financial  Statements Act paragraph 99 a, including:  · compliance with the ESRS;  · preparing the disclosures as included in the section âEU  taxonomyâ, pages 79-88, in compliance with Article 8 of the  Taxonomy Regulation;  · designing, implementing and maintaining such internal control  that management determines is necessary to enable the  preparation of the Sustainability Statement that is free from  material misstatement, whether due to fraud or error; and  · the selection and application of appropriate sustainability re-  porting methods and making assumptions and estimates that  are reasonable in the circumstances.  Inherent limitations in preparing the Sustainability  Statement  In reporting forward-looking information in accordance with  ESRS, management is required to prepare the forward-looking  information on the basis of disclosed assumptions about events  that may occur in the future and possible future actions by the  Group. Actual outcomes are likely to be different since antici-  pated events frequently do not occur as expected.  Auditorâs responsibilities for the assurance  engagement  Our responsibility is to plan and perform the assurance engage-  ment to obtain limited assurance about whether the Sustainabil-  ity Statement is free from material misstatement, whether due  to fraud or error, and to issue a limited assurance report that  includes our conclusion. Misstatements can arise from fraud or  error and are considered material if, individually or in the aggre-  gate, they could reasonably be expected to influence decisions  of users taken on the basis of the Sustainability Statement as a  whole.  As part of a limited assurance engagement in accordance with  ISAE 3000 (Revised) we exercise professional judgement and  maintain professional scepticism throughout the engagement.  Our responsibilities in respect of the Process include:  · Obtaining an understanding of the Process, but not for the  purpose of providing a conclusion on the effectiveness of the  Process, including the outcome of the Process;  · Considering whether the information identified addresses the  applicable disclosure requirements of the ESRS; and  · Designing and performing procedures to evaluate whether  the Process is consistent with the Groupâs description of its  Process, as disclosed in the section titled âDescription of the  processes to identify and assess material impacts, risks and  opportunitiesâ, page 57.  Our other responsibilities in respect of the Sustainability State-  ment include:  · Identifying where material misstatements are likely to arise,  whether due to fraud or error; and  · Designing and performing procedures responsive to disclo-  sures in the Sustainability Statement where material misstate-  ments are likely to arise. The risk of not detecting a material  misstatement resulting from fraud is higher than for one  resulting from error, as fraud may involve collusion, forgery,  intentional omissions, misrepresentations, or the override of  internal control.  Summary of the work performed  A limited assurance engagement involves performing proce-  dures to obtain evidence about the Sustainability Statement.  The nature, timing and extent of procedures selected depend on  professional judgement, including the identification of disclo-  sures where material misstatements are likely to arise, whether  due to fraud or error, in the Sustainability Statement.  In conducting our limited assurance engagement, with respect  to the Process, we:  · Obtained an understanding of the Process by performing  inquiries to understand the sources of the information used by  management; and reviewing the Groupâs internal documenta-  tion of its Process; and  · Evaluated whether the evidence obtained from our proce-  dures about the Process implemented by the Group was  consistent with the description of the Process set out in the  section titled âDescription of the processes to identify and  assess material impacts, risks and opportunitiesâ, page 57.  In conducting our limited assurance engagement, with respect  to the Sustainability Statement, we:  · Obtained an understanding of the Groupâs reporting process-  es relevant to the preparation of its Sustainability State-  ment, including the consolidation processes, by obtaining an  understanding of the Groupâs control environment, processes  and information systems relevant to the preparation of the  Sustainability Statement but not evaluating the design of  particular control activities, obtaining evidence about their  implementation or testing their operating effectiveness;  · Evaluated whether the information identified by the Process is  included in the Sustainability Statement;  · Evaluated whether the structure and the presentation of the  Sustainability Statement are in accordance with the ESRS;  · Performed inquiries of relevant personnel and analytical  procedures on selected information in the Sustainability State-  ment;  · Performed substantive assurance procedures on selected  information in the Sustainability Statement;  · Where applicable, compared disclosures in the Sustainability  Statement with the corresponding disclosures in the Financial  Statements and the Management review;  · Evaluated the methods, assumptions and data for developing  estimates and forward-looking information; and  · Obtained an understanding of the Groupâs process to identify  taxonomy-eligible and taxonomy-aligned economic activi-  ties and the corresponding disclosures in the Sustainability  Statement.  Other matter  The comparative information included in the Sustainability  Statement was not subject to an assurance engagement. Our  conclusion is not modified in respect of this limitation of scope.  </arr:AuditorsReportOnSubstainabilityReport>
<arr:SignatureOfSubstainabilityAuditorsPlace contextRef="ctx43" id="fact1628" xml:lang="en">Hellerup</arr:SignatureOfSubstainabilityAuditorsPlace>
<arr:SignatureOfSubstainabilityAuditorsDate contextRef="ctx43" id="fact1629">2025-03-05</arr:SignatureOfSubstainabilityAuditorsDate>
<cmn:NameOfAuditFirmSubstainability contextRef="ctx53" id="fact1666" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirmSubstainability>
<cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx53" id="fact1668">33771231</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx53" id="fact1669" xml:lang="en">Tue Stensgård Sørensen</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx53" id="fact1670" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx53" id="fact1672" xml:lang="en">mne32200</cmn:fIdentificationNumberOfSubstainabilityAuditor>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx54" id="fact1673" xml:lang="en">Jacob Brinch</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx54" id="fact1674" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx54" id="fact1676" xml:lang="en">mne35447</cmn:fIdentificationNumberOfSubstainabilityAuditor>
</xbrli:xbrl>