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<mrv:CorporateGovernanceReport contextRef="ctx-1" id="f1__s10__8__29" xml:lang="en">Corporate governanceGovernance structureThe shareholders of Novo Nordisk exercise their rights at the general meeting, which is the supreme governing body of the company. General meetings may be held annually and extraordinarily. While the Annual General Meeting, inter alia, adopts the companyâs Articles of Association, approves the Annual Report and elects the Board of Directors, an Extraordinary General Meeting serves a specific purpose. On 14 November 2025, Novo Nordisk held an Extraordinary General Meeting to elect new members to the Board of Directors. At the Extraordinary General Meeting, seven members of the then Board of Directors stepped down, whilst four new members were elected to the Board of Directors. Following the election at the Extraordinary General Meeting, less than half of the shareholder-elected Board members (two of five) are considered independent. It is the intention of the Board to increase the number of independent Board members to at least four at the Annual General Meeting in March 2026 at which point more than half of the shareholder-elected Board members will accordingly be considered independent. Any shareholder has the right to raise questions at general meetings. Resolutions can generally be passed by a simple majority. However, resolutions to amend the Articles of Association require two-thirds of the votes cast and capital represented, unless other adoption requirements are imposed by the Danish Companies Act. Novo Nordisk has a two-tier management structure consisting of the Board of Directors and Executive Management. The governance structure and rules of Novo Nordisk are further described in our Articles of Association and our Corporate Governance Report, both available at: www.novonordisk.com/about/corporate-governance.html.Foundation ownershipNovo Holdings A/S, a Danish company wholly owned by the Novo Nordisk Foundation, holds the majority of votes at Novo Nordisk A/Sâ general meetings. The combination of foundation ownership and stock listing enables Novo Nordisk to embark on long-term sustainable strategies while maintaining short-term transparency on performance. Our foundation ownership supports the overarching imperative to be both commercially successful and responsive to the wider needs of society. The Novo Nordisk Foundation has four objectives: to provide a stable basis for the commercial and research activities of Novo Nordisk, Novonesis and additional companies in Novo Holdingsâ investment portfolio; to support physicological, endocrinological, metabolic and other medical research; to support research hospital activities within diabetes in Denmark; and to support scientific, humanitarian and social purposes. Please refer to the section on value creation on page 10. For more information about the ownership structure of Novo Nordisk, see page 18.Corporate governance reportingNovo Nordisk reports in accordance with the Danish Corporate Governance Recommendations, which are implemented by Nasdaq Copenhagen in the Nordic Main Market Rulebook for Issuer of Shares, as well as the Corporate Governance Standards of the New York Stock Exchange applicable to foreign private issuers. Novo Nordisk complies with the Danish Corporate Governance Recommendations because we account for which recommendations we comply with or deviate from and explain our chosen approach. Find further information about our corporate governance practices and a statement on our approach to each of the Danish Corporate Governance Recommendations as well as the Corporate Governance Standards of the New York Stock Exchange in our Corporate Governance Report, are available at: www.novonordisk.com/about/corporate-governance.htmlRemuneration Executive remuneration is linked to financial performance as well as non-financial performance (e.g., innovation and sustainability). Both short- and long-term incentive programmes include sustainability metrics, aligning executive pay with our sustainability objectives. Novo Nordisk has prepared a separate Remuneration Report describing the remuneration awarded or due during 2025 to the Board of Directors and Executive Management members registered with the Danish Business Authority. The Remuneration Report is submitted to the Annual General Meeting for an advisory vote. The Remuneration Policy and the Remuneration Report are available at: www.novonordisk.com/about/corporate-governance.htmlDisclosure regarding change of control provisions It is disclosed that Novo Nordisk does not have any material contracts that take effect, alter or terminate upon a change of control of Novo Nordisk following implementation of a takeover bid. In the event of termination â whether by Novo Nordisk or by the individual â due to a merger, acquisition or takeover of Novo Nordisk, members of Executive Management registered with the Danish Business Authority are, in addition to the notice period, entitled to a severance payment of 24 monthsâ base salary plus pension contribution.Ethics and complianceIn Novo Nordisk, we have an ethics and compliance programme comprised of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme. Data privacy is a key component in our ethical principles, ensuring guardrails are in place to manage and mitigate risks, thus safeguarding our patients and society at large. We have also adopted set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. Our global AI Ethics compliance framework sets out principles, requirements and operational guidelines, while also cataloguing all deployed AI systems across the organisation. The framework standardises risk assessment processes and strengthens organisational capabilities through AI literacy training. Find more information about these principles, in accordance with the Danish Financial Statements Act Section 99d, at: www.novonordisk.com/data-privacy-and-user-rights/data-ethics.htmlSustainability governanceThe Board of Directors oversees sustainability, including material impacts, risks and opportunities (IROs), culture and business conduct. These matters are addressed through dedicated reviews and regular updates from Executive Management and the Audit Committee. The Board is supported by its committees: the Audit Committee oversees financial and sustainability reporting, due diligence outcomes and risk management; the Remuneration Committee integrates sustainability metrics into executive incentives; and the People & Governance Committee ensures board competencies align with business conduct and sustainability needs. These responsibilities are formalised in the Committee charters. While Executive Management sets and monitors the progress of the sustainability targets and strategy, the operational responsibility is anchored in Corporate Sustainability within the CEO Office. Corporate Sustainability works with business units to integrate environmental and social considerations into strategy, risk management and the product lifecycle. The Board ensures it has access to the skills and expertise needed to oversee sustainability matters and address Novo Nordiskâs material sustainability IROs during the reporting period.</mrv:CorporateGovernanceReport>
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<mrv:SustainabilityReport contextRef="ctx-1" id="f1__s10__8__31" xml:lang="en">Sustainabilitystatement1. General information1.1 Sustainability strategy and highlightsAt Novo Nordisk, we focus on creating lasting value for society and our business with a strong commitment to our triple bottom line: our financial, social and environmental responsibility. Building on the results of our double materiality assessment (DMA), the Sustainability statement outlines prioritised topics and other material topics to demonstrate this commitment. 1We aim to support patients, society and vulnerable populations by enhancing quality of life. In 2025, we reached an all-time high of 45.6 million people with obesity and diabetes care products. The number of vulnerable patients reached with our diabetes products decreased by 15% compared to 2024, due to reducing insulin tender sales caused by portfolio consolidation. We remain committed to improve access and affordability via targeted programmes and innovations, ®while ensuring patient protection. In the US, we increased our efforts through NovoCare, direct-to-patient offerings and telehealth partnerships. For prevention, we advanced early intervention for childhood overweight and obesity in urban areas with UNICEFâs programmatic activities benefitting more than 468,000 children. We continued our focus on being a sustainable employer in a year where Novo Nordisk launched a company-wide transformation to simplify the organisation, speed up decision-making, reduce cost and redirect resources towards obesity and diabetes growth opportunities. We maintained a focus on diversity and inclusion and launched a new strategy to leverage employee differences and foster an engaged workforce. We monitored the gender distribution across leadership levels and observed that the transformation process had minimal effect. We remain committed to protecting the health and safety of our employees and maintained a stable performance in 2025. Targeted awareness training and new construction safety standards for expansion and construction sites were implemented to safeguard employees and further enhance our performance.We remain committed to reducing our plastic footprint and our overall environmental footprint, with targets to reach zero scope 1 and 2 emissions by 2030, and a 33% reduction of scope 3 emissions by 2033. We aim to reach net zero GHG emissions by 2045. In 2025, scope 1, 2 and 3 emissions increased by 19% as expected due to planned expansions and increased energy use at new and growing production sites. We are continuing the advancement of key decarbonisation levers to stay on track towards our committed targets. We also made tangible progress by sourcing more than 10% of our glucose from regenerative agriculture, one of our levers to help us reduce scope 3 emissions in the future. 1. See definition of vulnerable patients reached with diabetes care products in the accounting policy on p. 561.2 Basis for preparation of the Sustainability statementGeneral reporting standards and principlesOur Sustainability statement is prepared in accordance with the European Sustainability Reporting Standards (ESRS) as required by the Danish Financial Statement Act. Information derived from other EU legislation is listed in the 'Additional Sustainability statement information section', p. 133, Table 2. Certain disclosures have been prepared with reference to other sustainability reporting standards, such as the Taskforce on Climate-related Financial Disclosures (TCFD), Global Reporting Initiative (GRI) Standards and Sections 99d and 107d of the Danish Financial Statements Act. We also align with other guidance frameworks such as the Greenhouse Gas (GHG) Protocol, Science Based Targets initiative (SBTi) and the Science Based Targets Network (SBTN). As an early adopter of the Taskforce on Nature-related Financial Disclosures (TNFD), we align with the material TNFD core global disclosure indicators. While quantitative indicators on global spatial footprint, land-use change and the state of nature are material to our roadmaps, limited data availability currently prevents disclosure. We are improving data quality to enable future reporting on these indicators. ISSB IFRS S1 and IFRS S2 have been considered in the preparation of this statement. In July 2025, the European Commission adopted a Delegated Regulation (EU) 2025/4812 extendingESRS phase-in provisions for wave 1 undertakings, which we applied. We also apply transitional provisions for selected value chain information; see the relevant topical sections for further details. We have not opted to omit any information related to intellectual property, know-how, innovation outcomes, impending developments, or ongoing negotiations. Table 3 in the Additional Sustainability statement Information (see p. 134) lists all ESRS requirements with which we comply. The time horizons applied in preparing the Sustainability statement follow ESRS guidance: up to one year (short-term), one to five years (medium-term), and more than five years (long-term). Unless indicated in the action tables, the action is not linked to a target. We continuously assess and secure the financial and non-financial resources needed to deliver our sustainability actions and meet targets across sustainability topics. EU Taxonomy disclosures are prepared in accordance with the EU Taxonomy Regulation and the amended Disclosures Delegated Act (EU) 2026/73.Sources of estimation and outcome uncertainty Metrics for our own operations are mainly based on primary data, while value chain metrics rely more on estimates and therefore carry greater uncertainty. Assumptions, uncertainties and estimates are described in the relevant accounting policies. Forward-looking information, including targets, is inherently uncertain; see the forward-looking statements on p. 17 for details.Changes in preparation and presentation of sustainability informationHistorical data are restated when prior-period errors or changes in accounting policies exceed the materiality threshold. Restatements mainly reflect methodological improvements or new evidence that enhances reporting accuracy. In 2025, the following metrics were restated due to improved calculation methods, correction of prior-period errors, or alignment with the new segment split used for financial reporting purposes: 1) split of number of employees (headcount) in geographical areas, 2) gender pay gap, 3) total energy consumption from renewable sources and its sub categories, 4) base and target year values for our scope 3 target, 5) SVHCs leaving facilities and 6) base and target year values for our plastic target. For more information, see sections 3.1 'Working conditions', 3.3 'Equal treatment and opportunities for all', 4.1 'Climate mitigation, adaptation and energy', 5.1 ' Resource inflow, outflow and waste' and 8.1 'Substances of very high concern'. We continuously work on improving our metrics. Comparative figures Comparative figures for 2023 are provided only where metric definitions and scope align with ESRS requirements. We have replaced the metric âmembership fees paid to trade associations,â first reported last year in section 9 Business conduct, with the data point âAmount disclosed in the EU Transparency Registerâ (see section 9.4 Political influence and lobbying activities, p. 77) to reflect information that is already publicly available.Risk management and internal controls over sustainability reportingSustainability reporting risks and controls are assessed annually. Data owners evaluate risks related to sustainability data, while a global function maintains the overall risk assessment and determines the required level of internal controls based on the nature of the risk and severity. The risk assessment covers risks of incomplete or inconsistent sustainability reporting, including data accuracy issues and manual errors during consolidation. A centralised online repository is used to document financial and sustainability risks and controls, applying a risk-based approach prioritising controls for higher-risk data points. Executive Management is responsible for the overall internal controls. The Disclosure Committee, established by Executive Management, reviews sustainability reporting changes in the Company Announcement quarterly. The Audit Committee oversees financial and sustainability reporting and is informed quarterly of actions and progress on key sustainability metrics and targets. Novo Nordisk Group Internal Audit conducts independent audits to evaluate the design and operating effectiveness of risk and control processes related to reporting.Statement on sustainability due diligence The table outlines our sustainability due diligence processes and the location in the statement.Core elements of environmental and social due diligence Pagesa) Embedding due diligence in governance, strategy and business model 40, 47-49, 134b) Engaging with affected stakeholders in key steps of due diligence 48, 52, 55, 57, 71, 75-77, 13448-51, 57, 63, 68, 71-72, 74, c) Identifying and assessing adverse impacts7552-56, 58-60, 64-65, 68-69, d) Taking actions to address those adverse impacts71, 73, 74, 7752-54, 56, 58-61, 64-66, e) Tracking effectiveness of these efforts and communicating69-71, 73, 74, 76-78Updated reporting structureThe reporting structure for 2025 has changed compared to 2024. Whilst acknowledging the prescribed structure in the ESRS (see visualisation on p. 44), the Sustainability statement now presents the prioritised topics first, followed by other material topics to guide readers to the most material, decision-relevant topics first.Basic information and references within the Sustainability statementScope of consolidation and organisational boundaries ⢠Scope is the same as the Consolidated Financial Statements.⢠For GHG emissions and pollution the operational scope is defined based on financial control.⢠NNE is excluded from 'Own workforce' policies, actions and targets as it operates under a different business model and thereby follows own processes.Value chain inclusion⢠Material IROs across our own operations and the up- and downstream value chain are addressed. ⢠The inclusion of our value chain in policies, actions and targets is determined by our double materiality assessment.⢠A visualisation of our value chain is provided in the section 'Value creation' on p. 10. Incorporation by reference ⢠See Table 4 in 'Additional Sustainability statement information' on p. 134.1.3 Interests and views of stakeholdersNovo Nordisk strives to understand and reflect the interests of key internal and external stakeholders in order to create lasting value for society and our business. As a global company, we depend on numerous stakeholder groups, which we have divided into six categories, to ensure that we deliver on our Strategic Aspirations with due consideration of our impact. We ensure that the interests and views of our stakeholders are taken into account through relevant due diligence processes and regular interactions as part of our business activities. The interests and views of stakeholders inform anything from daily business activities to our review of the corporate and sustainability strategy as set by Executive Management and the Board of Directors.Stakeholder groupPatient organisations, healthcare professionals and healthcare organisationsEmployeesSuppliers and third-party representativesGovernments, public officials and regulatorsPartners and peersInvestorsPurpose and engagement channels We take a patient-centred business approach to improve prevention, detection, treatment and access to quality care for people living with serious chronic diseases. We deliver on these efforts through for example research collaborations, clinical trials, conferences and scientific and medical communications.We strive to continuously improve the health and safety of our employees, as well as provide equitable opportunities and competitive working conditions, in order to attract and retain talent. Interests and views are obtained via our annual employee survey, individual career development, workersâ councils, Novo Nordisk Way facilitations, the Ombudsman function, etcWe depend on suppliers and third-party representatives, for example when purchasing goods and services to manufacture or distribute products and and when partnering on activities such as filling or assembling final products or performing clinical trials. Our Responsible Sourcing Programme, supplier audits and established contracting processes drive our engagement.We advance public health issues and ensure early awareness of regulatory developments and standards by organising and sponsoring events, engaging with industry associations and driving bilateral dialogues with local, national and international agencies and authorities.We seek perspectives from partners and peers to advance our commitments, with the aim of having long-term impacts and improving the resiliency of systems and communities that we are a part of. We take a multi-level approach to partnerships and collaborate with different actors such as NGOs, academia and other industry partnerships across our social and environmental efforts.We strive to provide timely, accurate and transparent information to our investors through engagements such as Capital Markets Day, the Annual General Meeting, ESG rating providers and recurring engagement in response to investor queries.Examples of how outcomes are taken into account⢠Development of new treatments and product improvements, see section '2.1 Innovation' p. 52 ⢠Protecting the quality and safety of our products and product communication, see '2.3 Patient protection' on p. 55⢠Foster a culture of safety with attention to increasing employee health and total wellbeing, including new measures to address symptoms of stress, see '3.2 Health and safety' p. 59⢠Update of our Global strategy on Diversity, Equity, Inclusion and Belonging to leverage our differences and further drive innovation, see '3.3. Equal treatment and opportunities for all' p. 60⢠Integration of responsible sourcing principles into contracts with our business partners, see 'Workers in the value chain' p. 71⢠Partnering with suppliers on low-carbon materials and feedstocks, see actions in section 4 'Climate change' p. 65⢠Advocacy on issues related to therapy areas that can help address global health challenges, see '9.4 Political influence and lobbying activities' p. 77 ⢠Prevent childhood obesity through UNICEF partnership and reduce risk of lifetime cardiometabolic diseases through the Childhood Obesity Prevention Initiative with partners such as cities and academic institutions, see '2.2 Social responsibility: prevention and access', p. 53.⢠Advance our environmental commitments, for example through partnerships on lower carbon plastics, see 'Resource use and circular economy' p. 68⢠Improved sustainability disclosure transparency through investor feedback.⢠Learnings from engagement with ESG rating providers to improve ESG performance, see latest performance in margin to the right.1.4 Double materiality assessment Outcomes of the 2025 double materiality assessmentThe double materiality assessment (DMA) determines the scope of the Sustainability statement, ensuring the focus is on the impacts, risks and opportunities (IROs) that are material to Novo Nordisk and our stakeholders. An overview of the material IROs is shown on p. 50.Our 2025 DMA resulted in four prioritised topics: patient protection and quality of life (S4), own workforce (S1), climate change (E1) and resource use and circular economy (E5). These topics are 1) double-material, 2) have scored the highest in our DMA and 3) are linked to our Strategic Aspirations. Our core social responsibility is to help improve quality of life and provide healthcare for people around the world. Our efforts involve ensuring access to life-saving medicines without compromising safety or quality for patients and vulnerable populations. We acknowledge that the manufacturing of our medicines generates certain environmental impacts across our own operations and our upstream supply chain, particularly GHG emissions, energy use and the use of plastics and other resources. We are working to reduce our material impacts, including in raw material sourcing, production processes and packaging, while continuing to identify opportunities to improve circularity and resource efficiency throughout our downstream distribution and product-use phases.The DMA resulted in five other material topics that are essential for how we produce our medicines safely, reliably and with the highest ethical standard: workers in the value chain (S2), nature incl. water and biodiversity (E3 and E4), pollution (E2) and business conduct (G1). Our dependencies on an extensive global supply chain, chemical inputs and nature-based resources reinforce the materiality of these topics and our obligation for transparent disclosure of our impacts. Strong ethical conduct and governance are fundamental to maintaining trust with our regulators, partners and society, and sustains our licence to operate. Only minor refinements have been made since the 2024 Sustainability statement, mainly to clarify and reclassify certain IROs. As part of this update, the following sub-topics have been descoped for 2025: substances of concern (E2), severe human-rights-related impacts (S1) and equal-opportunities-related topics (S2). For the new IROs added in 2025, see the IRO table-overview, and for non-material topics for 2025 see footnote on p. 50. Interaction with company strategy and business modelTo assess strategic resilience, sustainability is considered as part of our strategy review. ExecutiveManagement and the Board of Directors annually review strategic risks and opportunities within and beyond a five-year horizon, ensuring our strategy continues to meet societyâs needs (see section 'Risk management' on p. 41 for further details). These resilience discussions draw on cross-organisational input and focus on sustainability matters that influence our long-term direction, such as reaching underserved populations and reducing environmental impacts. Sustainability considerations are embedded in the relevant strategies and discussed on an ongoing basis with Executive Management.Processes to identify and assess material impacts, risks and opportunitiesIn 2025, we updated our double materiality assessment to identify Novo Nordiskâs material impacts, risks and opportunities across the value chain, in line with ESRS 2 IRO-1. The DMA covers both impact materiality, i.e. how our activities affect people and the environment, and financial materiality, i.e. assessing how sustainability-related risks and opportunities influence Novo Nordiskâs development, performance and position. The process is reviewed annually as part of disclosure preparations.The process started with the AR16 sustainability matters list and entity-specific topics were identifiethrough screening tools, utilising sources such as public reports, regulatory development, as well avoluntary standards. Stakeholder perspectives informed the assessment. These inputs were drawn by proxy from internal subject-matter experts who engage with stakeholders as part of their daily areas of responsibility, complemented by external value-chain insights gathered in 2024.In 2025, subject- matter expert workshops were used to pressure-test and refine the list of impacts,risks and opportunities, considering geographic, operational and due-diligence factors as well as business developments. The process combined bottom-up insights with top-down leadership calibration and concluded with an Audit Committee review. Control procedures included documentation of reviews, validation by subject-matter experts and cross-functional governance to ensure consistency and quality of judgments.Materiality judgements were based on a structured five-point scoring framework in line with ESRS 1Severity, likelihood (of potential impacts) and financial effect were assessed. For human rights matters, severity outweighs likelihood. Interdependencies across impacts, risks and opportunities were evaluated jointly with internal experts. Scoring was conducted at the most granular level and aggregated for reporting.Impact materiality was assessed using scale (magnitude), scope (reach) and irremediability, supported by quantitative indicators for environmental matters. Financial materiality aligned with Novo Nordiskâs Enterprise Risk Management (ERM) approach but applied longer time horizons and assessed risks on a gross basis. Financial effects were evaluated using qualitative and quantitative scales across monetary, reputational, ethical and quality dimensions.Thresholds were applied to determine materiality. For impact materiality, topics rated critical, significant or important and deemed to be current were considered material. Financial materiality applied the same approach, but impact materiality intentionally applied lower thresholds than financial materiality (significant and above), ensuring that a broader range of impacts on people and the environment were captured. For potential impacts, risks and opportunities, a heatmap was used to determine materiality. Borderline cases were discussed with management. We continuously assess how sustainability is considered in our overall risk profile to strengthen integration.Material impacts, risks and opportunitiesThe illustration provides an overview of the identified material IROs, categorised into prioritised topicsand other material topics. Each IRO has a number, and the illustration below indicates the IROsâ position in Novo Nordiskâs value chain, along with the associated time horizon (one year, five years or more than five years). The illustration also highlights where to find further details about our IROs in the topical sections of the Sustainability statement.2. Patient protection and quality of lifeIRO name Category Sustainability topic Value chain locationImproving quality of life⢠Downstream⢠InnovationPotential new discoveries ⢠Own operations⢠DownstreamHealth promotion and prevention ⢠Downstream⢠Social Health equity in clinical trials and for responsibility: ⢠Own operationsvulnerable patientsprevention ⢠Downstreamand accessPotential reputational risks related to ⢠Own operationsaccess effortsProduct quality and safety, including ⢠Own operationsclinical trials⢠DownstreamProtection of patient safety against ⢠Downstreamillicit trade of our medicines⢠Patient Protection of clinical trial and patient protection⢠Own operationsinformation⢠DownstreamPotential regulatory and reputational ⢠Own operationsrisks linked to patient protection and ⢠Downstreamclinical trial participantsMaterial impacts, risks and opportunitiesAs a pharmaceutical company, our end-users not only include the people we serve and our patients, but also clinical trial participants, healthcare- providers and systems. While the following chapter primarily refers to patients, the IROs should be understood in the broader context of all our end-users. To address our patient-related sustainability matters, we have split the chapter into three connected sections, each addressing specific IROs. We take the point of departure in how we develop innovative treatments (Innovation) to support long-term health. Social responsibility: prevention and access covers the initiatives and programmes enabling those treatments to reach the patients who need them. Patient protection is the guiding principle throughout our operations, ensuring that safety and quality standards govern every stage from discovery to delivery. .InnovationNovo Nordisk adds value to society and creates material positive impacts for people through discovering and developing innovative products to address unmet medical needs. As we continuously strive to set new standards for innovation through AI-supported R&D and digital technologies, we strengthen our ability to innovate, discover and create opportunities to improve the lives of patients.Social responsibility: prevention and accessNovo Nordisk takes a comprehensive approach to social responsibility, combining prevention efforts with actions to improve the access to and affordability of our products. Defeating chronic diseases depends on tackling root causes, which is why we focus on prevention. With a focus on children and vulnerable populations, our initiatives have the potential to positively impact society and patients by improving health and wellbeing, and addressing shared risk factors across cardiometabolic diseases.We remain committed to creating positive impact by expanding access to our products, improving affordability as well as supporting vulnerable populations and children with serious chronic diseases in low- and middle-income countries. Access is also central to our clinical trials, enabling our clinical programmes to adequately represent the patient population affected by the diseases we study and treat. We recognise that persistent health inequities pose material reputational risks, and we continue to collaborate with relevant stakeholders, such as policymakers and health authorities, to expand access to affordable care. Patient protectionSafeguarding patient safety and product quality is our highest priority. We strive to mitigate any negative health impacts associated with clinical trial participation or marketed products. This includes our continuous fight against illicit trade to protect patients from serious health risks of counterfeit, diverted or illicitly compounded medicines.Protecting patients from information-related impacts, such as data privacy and adequate product information, is central to our business. As we rely on health data in research and increasingly adopt AI in our operations, we remain committed to safeguarding personal data. We aim to provide transparent and responsible information on our products and clinical trials to support optimal treatment choices. Any failure to protect patients would represent both a material negative impact and a risk to Novo Nordiskâs business and reputation. For this reason, we never compromise on safeguarding patients from adverse impacts.2.1 InnovationPolicies and approachBuilding on more than a century of scientific knowledge, we are committed to promoting long-termhealth by developing treatments across the spectrum of cardiometabolic health as well as within rare diseases. Our innovation in GLP-1 medicines delivers benefits beyond glycaemic control â including weight loss and lower risks of cardiovascular events, improving outcomes for the people we serve and for society. Beyond GLP-1 medicines and across R&D programmes, our goal is to meet the unmet need in obesity and diabetes with therapies that deliver durable, meaningful improvements in health and quality of life. These efforts are guided by our OneCode policy, which reflects our patient-centred commitment and sets requirements for how we act across policies and procedures. OneCode is continuously monitored and updated to reflect the evolving regulatory landscape and safeguard our licence to operate.As a testament to our purpose, we respect the human rights of our patients as outlined in our Human Rights Commitment (see section 6 'Workers in the value chain', p. 71). In cases where we cause or contribute to human rights impacts, we commit to providing remedy. For more information on our Compliance Hotline see section 9.2 on p. 76. Guided by our Patient Voice Strategy, we take a patient-centric approach, collaborating with patients and their legitimate representatives throughout the product life cycle, adapting engagement based on development stage and therapy area. We use various channels, including advisory boards, workshops and surveys to gather insights from respondents at frequencies based on need. This engagement process, overseen by two chief patient officers, ensures that insights from patients and care partners are embedded in decision-making to drive ongoing improvements, enhance disease understanding, meet real-world needs and deliver better outcomes.The adoption of AI in our R&D processes aims to accelerate discovery and development of new treatments, shortening time to market and expanding access to care. Safeguards for data protection in relation to AI are detailed in section 2.3 'Patient protection' p. 55. Actions We invest strategically across our R&D value chain and through business development. Building on decades of leadership in incretin biology, our R&D pipeline includes key assets such as CagriSema, a once-weekly combination therapy in phase 3 trials, and continues to deliver breakthrough results, most recently demonstrated by the FDA approval of the oral semaglutide ® 25 mg ('the Wegovypill'). Opportunities to accelerate innovation within our therapy areas are further outlined in 'Innovation and therapeutic focus', see p. 26-31. While we are strengthening our pipeline to improve outcomes for people with obesity, diabetes and related comorbidities, we are adapting our commercial strategy to better serve patient needs and expand access (see graph 2.1.1 to the right). Our commercial execution is adapting to reflect those evolving needs by integrating digital pathways, expanding pharmacy and telehealth partnerships, while promoting appropriate use to ensure safe, accessible and effective care. For more details on how we translate our discoveries into real-world outcomes through commercial delivery, read our chapter on 'Commercial execution' on p. 20-25. We consider sustainability in our product development process by estimating and informing on the social and environmental profile of each project throughout the product lifecycle. We aim to improve how we use sustainability information as part of product development and decision-making processes.PerformancePatients reached is a key performance indicator for tracking progress and impact for our actions. The number of patients treated with Novo Nordiskâs obesity and diabetes care products is monitored to estimate our global positive impact of improving quality of life through medicine. The total number of patients reached in 2025 remained at a similar level to 2024. The number of patients reached with diabetes care products decreased by 2% due to lower sales of human insulin products. However, we increased the number of patients reached with diabetes GLP-1 products and new-generation insulin by 10% in 2025 compared to 2024. The number of patients treated with obesity care products increased significantly by 64%, mainly ®driven by Wegovy expanding reach in existing markets and launched in 35 new markets in 2025. Patient reach is calculated based on annual usage dose per patient. Therefore, this method does ®not count the actual number of individuals on Wegovy, since treatment duration may be shorter than a full year. 2.2 Social responsibility: prevention and accessPolicies and approachAs part of social responsibility, we invest in evidence-based health promotion and primary prevention of serious chronic diseases targeting vulnerable populations. We have a specific focus on the prevention of the shared risk factors across cardiometabolic diseases including overweight, obesity and type 2 diabetes. While we have no formal prevention policy, these activities are integrated into our therapy areasâ strategies and local affiliatesâ priorities.Novo Nordisk has publicly available position papers on access to diabetes care and medicine 1pricing. We advocate equal rights to healthcare for all and are committed to overcoming barriers to effective diabetes care in low- and middle-income countries. Our position on medicine pricing states that prices should reflect productsâ value to patients, society and the healthcare system, including factors such as the medical need met for clinicians and patients, improvement of short- and long-term health outcomes and quality of life. Other factors include the contracting, pricing and reimbursement system of a given country. We acknowledge global affordability challenges, including in high-income countries, and collaborate with policymakers and health authorities to find solutions to ensure affordable access for all patients.In line with our OneCode policy, we also advance access and representation in clinical research. Internal procedures ensure that we plan, design and execute trials representative of the diseases we study to build confidence in the safety and efficacy of our products. Actions Our social responsibility programmes and initiatives focus on advancing prevention, access and affordability for vulnerable populations and children. The impact of our work is measured across initiatives and performance indicators, with increasing efforts to evaluate the health-economic impact and social return on investment. Funding for our initiatives is anchored in our Social Responsibility team, with investments assessed through financial planning. Additional value is delivered via grants to non-profits organisations in the US through our internal Communities for Better Health programme as well as to health, sustainability and the life science ecosystem via the Novo Nordisk Foundation, our majority shareholder, through Novo Holdings A/S.Health promotion and prevention We drive action through public-private and multi-sector partnerships at individual, community and national levels, with a specific focus on urban environments. Together with global and local partners, including governments, NGOs and academic institutions, we address societal issues such as nutrition, physical activity, mental health and education through evidence-based interventions, documenting the shorter- and longer-term health-economic societal impact. As part of our in-house for-profit work, we are partnering with companies in biotech and digital health to develop technologies that identify individuals on a disease trajectory using risk predication insights.1. The position on access to diabetes care is aligned with the UN Universal Declaration of Human Rights Besides these ongoing actions, we have expanded our Cities for Better Health programme (see box to the right) and also implemented the following key actions in 2025:2025 actions Partnership with UNICEF⢠Prevent childhood overweight and obesity by fostering healthy environments through policy change, advocacy and innovation in food and urban systems. ⢠Countries with direct programmatic activities: Brazil, Columbia, Mexico and Indonesia.⢠From June 2024 - June 2025, more than 468,000 children under the age of 19 benefited from UNICEFâs local programmatic activities.Communities for Better Health⢠Prevent chronic diseases in vulnerable populations in the US by funding partners across 27 US states and Washington D.C., supporting initiatives that address food-related social determinants of health.⢠From August 2024 - September 2025, we invested over USD 20 millions in 29 projects, and our partners served up to 280,000 community members.Access to careWe collaborate with external partners to strengthen supply chains, expand access and build healthcare capacity. For vulnerable patient populations, we provide low- or no-cost programmes, alongside donations and contributions to access-related causes (see table 2.2.2 on the next page). Under our Access to Insulin Commitment, we have a ceiling price of USD 3 per vial in low- and middle-income countries (LMICs) and USD 2 per vial for humanitarian organisations, covering 77 countries 2 and 32 LMICs3(45 least developed countries). In rare disease, we partner with the Sickle Cell Disease community to improve access to continuous, affordable care. In sub-Saharan Africa, we collaborate with the Consortium on Newborn Screening in Africa (CONSA) and Reach52 to build capacity and capabilities, improve disease management and patient outcomes.In the US, we continue to support accessible routes to our medicines by offering rebates and discounts for insurers and other payers. We are strengthening direct-to-consumer pathways by ®expanding NovoCare, partnering with telehealth providers to broaden access and collaborating with retail pharmacies such as CVS to ensure continuity of care. In 2025, we reduced prices for self-pay patients and we are currently in discussion with the US Administration to further expand access to FDA-approved obesity and diabetes medicines for millions of Americans. Information on our ®patient-assistance programmes is available at our NovoCare website. Besides these ongoing actions, we have also implemented the following key actions in 2025 (see next page):2. Categorisation of the least developed as defined by the United Nations. 3. Categorisation of low- and middle-income countries as defined by the World Bank.2025 actions®Changing Diabetes in Children ⢠Provide diabetes care to children and youth with type 1 diabetes living in LMICs. This can include life-saving medicine, blood glucose monitoring equipment and medical supplies. ⢠Target: 100,000 children by 2030.⢠Metric: 2.2.1iCARE Integrated Business Model⢠Improve access to cardiometabolic care for vulnerable populations by embedding social responsibility into commercial objectives of affiliates guided by four pillars: capacity, affordability, reach and empowerment. ⢠It includes 49 countries in sub-Saharan Africa and Indonesia.⢠2024 Action on Access Innovation Incubator has been integrated into the iCARE model⢠In 2025, Indonesia implemented the iCARE model, which is now evolving into a holistic, cross-therapy approach in existing markets.⢠Metric: 2.2.3 Human Insulin Thermal Solutions (HITS) ®⢠Develop new flexible storage options for two human insulin products: Actrapid and ®Insulatard, to provide access to care for people with diabetes in settings where refrigeration is a challenge. ® and Insulatard®⢠In 2025, the accumulated number of label updates for Actrapid reached more than 40 countries, informing users of the new storage options. The ambition is to reach more than 50 countries, where the products are launched.⢠Metric: 2.2.3Clinical trialsWe implement trial and therapy area specific measures to advance representativeness in clinical research, including identifying and addressing potential enrolment and retention barriers. Through the IHI READI public-private partnership, we collaborate with key stakeholders with the aim of creating an inclusive clinical study ecosystem for underrepresented populations. We are expanding decentralised clinical trial elements to improve access, for example by enabling assessments to be conducted at the participantsâ preferred locations.Targets and performanceIn 2025, the number of vulnerable patients treated with our diabetes care products decreased by 15% (see graph 2.2.3 to the right) driven primarily by lower insulin tender sales caused by portfolio consolidation. Even though the overall number of vulnerable patients reached has decreased, the number of vulnerable patients reached with diabetes GLP-1 products has increased in 2025 compared to 2024. Looking ahead, we remain committed to our social responsibility and to develop solutions that meet diverse needs across geographies and health systems. We are aiming to reach 100,000 children with type 1 diabetes by 2030, building on our Changing ®Diabetes in Children (CDiC) programme launched in 2009. The programme spans 30 partner countries, with the target based on International Diabetes Federation (IDF) estimates of children with type 1 diabetes in LMICs. Local partners set milestones to improve diabetes care, while Novo Nordisk tracks progress quarterly through reports received by the local implementing partners. By the end of 2025, 81,946 children had been reached in total. The addition of 17,203 children during 2025 was due to new enrolments in primarily China, Morocco, Ethiopia and Pakistan which ensures we are on track to reaching our target. ® 2.2.1 Children reached through the Changing Diabetes programme (Number since 2009)Novo Nordisk pays out donations and other contributions to a variety of organisations and foundations, among others the World Diabetes Foundation (WDF) and NNHF. In accordance with our agreement, the contribution to WDF was DKK 121 million, an increase of 1% compared to 2024. Moreover, total donations paid out to NNHF increased by 12% to support ongoing projects. 2.2.2 Donations and other contributionsmDKK 2025 2024 2023World Diabetes Foundation (WDF) 121 120 119Novo Nordisk Haemophilia & Haemoglobinopathies Foundation 1(NNHF)29 26 19Total donations and other contributions 150 146 1381. Previously reported as Novo Nordisk Haemophilia Foundation (NNHF).2.3 Patient protection Policies and approachProduct quality and safetyPeople depend daily on the quality and safety of our products. Our quality management system ensures that we work in compliance with Good Practices (GxP) regulations and integrates quality into all processes. Our global pharmacovigilance system monitors and manages the safety profile throughout the productsâ lifecycle in line with regulatory requirements. These systems manage the information reported through our publicly available portals including product complaints, side effects or falsified products. For information on illicit trade, see margin to the right.4 Guided by national laws, international conventionsand our public position on clinical trial ethics, patient safety is central to our clinical trials and research. A cross-functional safety committee oversees safety data from the outset of our studies, providing assessments of safety data throughout the product or deviceâs lifecycle. Special consideration is given to vulnerable patient populations, including children and the elderly. If clinical research involves vulnerable patients, we evaluate whether the study should have an external Data Safety Monitoring Board to ensure independent safety review of the study. Information-related impactsWe rely on patients and clinical trial participant health data for clinical research. Data protection is embedded in our global governance framework, guided by our public data ethics standards, processing principles and global compliance framework with strengthened safeguards for patient and clinical trial data. We have also adopted a set of principles data and AI ethics, which is similarly embedded in our ethics and compliance framework to ensure ethical decision-making and risk management.Sharing clinical trial knowledge accelerates scientific progress and advances public health. Outlined in our disclosure and reporting instructions, we ensure that results from studies sponsored by Novo Nordisk are disclosed in public registers. Plain Language Summarises (PLS) of phase 3 publications are developed to improve accessibility of findings by translating complex scientific information into easy-to understand formats, in line with our standard operating procedures. Following trial completion, we work with local health authorities to ensure informative and accurate product labelling to guide patientsâ use. Processes for safeguarding labelling quality in the markets in which Novo Nordisk operates are outlined in standard operating procedures. We only promote and communicate responsibly about our products for uses that have been approved by regulatory authorities in a manner that is truthful, accurate, non-misleading, balanced and consistent with the approved product label. Off-label promotion is prohibited as outlined in our OneCode policy.4. Including The Declaration of Helsinki, the International Conference on Harmonisation Guideline for Good Clinical Practice, Good Pharmacoepidemiology Practices, the Nuremberg Code, the UN Guiding Principles on Business and Human Rights, the Belmont Report and UNESCOâs Universal Declaration on Bioethics and Human Rights.Actions Protecting our patients from adverse impact underpins our licence to operate, with action plans implemented through organisation-wide programmes and activities.Product quality and safetyOur Customer Complaints- and Global Safety Department records, investigates and responds to safety data from clinical trials, side-effect reports and quality complaints concerning the quality, labelling, durability, reliability, effectiveness, safety, performance or malfunction of our products. This enables us to take timely and appropriate action and fulfil our reporting obligations to health authorities. Outcomes are monitored and addressed in our risk management system and a risk management plan is prepared. Effectiveness of our safety procedures is tracked through recalls and inspections (see table 2.3.1 on the next page).To protect the paediatric population in our clinical trials, we design these to minimise disruption to familiesâ daily lives. Paediatric plans are developed with guidance from our internal, multidisciplinary Paediatric Expert Group to ensure the safety and efficacy of our products for the paediatric populations.Information-related impactsWe act across the organisation to prevent and mitigate any information-related risks and impacts for patients and clinical trial participants while adhering to all relevant regulations. Management of AI-related risks to patients is continuously strengthened through AI Literacy and awareness building to develop competences across the company. In line with the EU AI Act and corporate requirements, all AI systems are assessed from an ethical standpoint to phase out unacceptable use cases. We completed an update of our Patient Information and Informed Consent (PIIC) forms to enhance general transparency with respect to engaging in our clinical trials and ensuring protection of our patients data and privacy.To ensure responsible communication, all promotional product materials undergo legal, medical and regulatory review. Our internal guidelines are continuously strengthened to ensure healthcare professionals receive accurate product information and clinical data for quality patient care.Besides these ongoing actions, we have also implemented the following key actions in 2025 (see next page):Illicit trade⢠Illicit trade encompasses a range of criminal activities including:⢠Counterfeiting⢠Illicit diversion ⢠Illicit compounding⢠These practices pose serious threats to patient safety, public health and business integrity. Policies and approach⢠Management of illicit trade is anchored in our OneCode policy and covered in our standard operating procedures and quality management system.⢠Our Prevent, Detect and Respond strategy outlines how we address potential adverse impacts of illicit trade e.g., educating global communities, driving efforts to reinforce regulations, maintaining supply chain integrity, detecting illegal products via patient/HCP complaints, field and online monitoring and responding to cases by reporting these to authorities and taking legal action, when relevant. ⢠Our positions on falsified medicines and illicit compounding of semaglutide provides further details on our principles.Actions⢠We have increased detection and takedowns of fraudulent online offers by expanding the scope of our proactive monitoring to address illicit trade risks. As a member of the Pharmaceutical Security Institute, Novo Nordisk also contributes to joint industry action.2025 actionsCapability building for combatting illicit trade ⢠We delivered targeted awareness sessions in most affected markets, training more than 1,500 law enforcement and customs officials.⢠Internally, over 2,000 employees responsible for incidents response were trained to report to authorities and ensure proactive engagement with regulators.⢠As a measure of effectiveness, an increase in law enforcement vigilance and information sharing was observed.Patient data protection and AI ⢠Enhance data ethics risk management across our processes, supplier interactions and use of AI technologies. The scope is global for relevant suppliers, systems and processes.⢠New AI clauses in contract templates were implemented, and the Data Protection Impact Assessment was refined across projects to 1) identify patient data protection risks and 2) implement actionable measures to mitigate these.Patient-centric lay language documents⢠Obtain and implement patient insights on our communication in lay language to enhance the comprehension and accessibility of clinical trial information. ⢠Lay language documents in clinical reporting were in scope for feedback from the established Innovation Patient Advisory Board. Based on the insights, relevant template updates will be rolled out in 2026.e-labelling ⢠Develop e-labelling to provide an additional channel for accessing labelling information and allowing for faster access to labelling updates (e.g., safety information updates) for end-users. e-labelling is applied in mandated or accepted markets.⢠In 2025, a global process for e-labelling was implemented.PerformanceTo manage product safety and quality risks, Novo Nordisk tracks product recalls. In 2025, four ®product recalls occurred; cracked cartridges of Ozempic in Canada, out-of-specification (OOS) ®dissolution results for Vagifem 10 micrograms in Canada and the Netherlands, errors in shipping documents sent to clinical trials in Italy and Greece, and the risk of biological particulate matter in ®Semaglutide (Wegovy) filling batches in the US. None of the recalls occurred at patient level or led to any health consequences. We monitor inspections to ensure regulatory compliance. In 2025, 171 inspections were conducted,of which 130 inspections were passed, 40 were in-progress, as final inspection reports had not yet been received, or the final authorityâs acceptance was pending. Follow-up on in-progress inspections will continue in 2026. In 2025, a US FDA inspection at the Bloomington site, recently acquired from Catalent, received an 'Official Action Indicated' (OAI) status and subsequent warning letter. We are working closely with US FDA to resolve the issues raised in this inspection and warning letter.2.3.1 Product recalls and failed inspectionsNumber 2025 2024 2023Product recalls 4 3 2Failed inspections 1 0 0ACCOUNTING POLICIES Patients reached with Novo Nordiskâs obesity and diabetes care productsEstimated by dividing Novo Nordiskâs net sales, samples and donations volume by the annual usage dose per patient for each product class, as defined by the WHO (for diabetes) or in accordance with the dose strength of the product (for obesity). Devices are excluded. Vulnerable patients reached with Novo Nordiskâs diabetes care productsVulnerable patients are estimated by using two methods: firstly, reach of one vulnerable patient is defined as sales volumes in low-, lower middle- or upper middle- income countries (LMICs) corresponding to an annual drug usage dose per patient as defined by WHO through public tender sales, products sold under affordability thresholds (based on World Bank data and local healthcare expenditures), humanitarian donations and for vulnerable patients reached in the US through products supplied in select programmes. Secondly, for US access and affordability programmes, reaching one vulnerable patient is defined at the time of enrolment based on patient programme reports. Due to different methodologies applied, vulnerable patients reached with diabetes care products are not fully to be considered a portion of overall patients reached.®Children reached through the Changing Diabetes in Children programme are estimated as the total accumulated number of children and youth enrolled since the initiation of the partnership in 2009. Children participating for multiple years are only included once in the year of enrolment. Children and youth are defined as 0-25 years old and living in poverty as defined by the World Bank.Donations and other contributionsThe monetary donations from Novo Nordisk to the World Diabetes Foundation (WDF) and the Novo Nordisk Haemophilia & Haemoglobinopathies Foundation (NNHF) are recognised when the donation or contribution is paid out.Product recallsNumber of times Novo Nordisk has instituted a recall of a product from the market due to patient safety reasons, including recalls in connection with clinical trials. A recall may affect multiple countries.Failed inspections Inspections where FDA warning letters or European Medicines Agency non-compliance letters related to Good Medical Practice inspections are received, Good Medical Practice/ISO certificates for strategic sites are lost, pre-approval inspections result in a complete response letter, study conclusions are changed due to Good Clinical Practice/Good Laboratory Practice inspection issues, or marketing or import authorisations are withdrawn due to inspection issues. Strategic sites are defined as the manufacturing sites in Brazil, China, Denmark, France and the US. Inspections at acquired companies run by Novo Nordisk are reported as Novo Nordisk inspections. Inspections of acquired companies run by the acquired company are excluded. PrioritisedtopicsPatient protection and quality of lifeOwn workforceClimate ChangeResource use and circular economyAmbitionBeing recognised as a sustainable employerPolicy Labour Code of ConductHealth and Safety policyDiversity and Inclusion policyPerformance ⢠Gender distribution in Senior Leadership was 56:44 (men/women)⢠The LTIR remained on par with the 2024 levelSub-topics:Own workforce is addressed in the following three sub-topics:⢠Working conditions⢠Health and safety⢠Equal treatment and opportunitiesFor more information on our Compliance Hotline, see section 9.2 on p. 763. Own workforceIRO name Category Sustainability topic Value chain locationFair working conditions⢠Working ⢠Own operationsconditionsProtection of health and safety⢠Working ⢠Own operationsconditionsEnsure equal treatment and ⢠Equal treatment ⢠Own operationsopportunitiesand opportunities⢠Working ⢠Own operationsPotential talent attraction risksconditions⢠Equal treatment and opportunitiesMaterial impacts, risks and opportunitiesNovo Nordisk depends on a skilled and diverse workforce across production sites, laboratories, commercial functions and administrative roles to deliver innovative treatments for people living with serious chronic diseases. Fair labour rights and employee benefits are a fundamental part of our workforce approach, supporting stable and attractive working conditions globally and safeguarding against negative impacts. Central to building an inclusive, diverse and resilient organisation, is protecting our employees health and safety and ensuring equal treatment and opportunities. Strong workforce practices and inclusive cultures help safeguard risks such as not attracting or retaining critical talent, particularly in R&D and specialised roles, which could undermine innovation and competitiveness. TransformationIn 2025, Novo Nordisk announced a company-wide transformation to simplify the organisation, speed up decision-making and redirect resources towards obesity and diabetes growth opportunities. The plan is designed to sharpen commercial execution, ensuring we remain competitive while upholding high standards of ethics and compliance. As part of this transformation, we have reduced around 9,000 positions globally of which 5,000 in Denmark. We recognise that organisational changes of this scale may affect fair labour rights and employee benefits. Maintaining a close dialogue with labour-market representatives and ensuring compliance with applicable labour regulations have therefore been key priorities throughout the transition. The process has been conducted in accordance with local labour-market requirements, with clear and timely communication to affected employees. We also acknowledges the importance of safeguarding health and safety during periods of change, ensuring that workforce considerations remain integral to our strategy. We take responsibility for ensuring that our actions do not cause harm, embedding the protection of employee rights, health and well-being into our policies and ways of working.3.1 Working conditionsPolicies and approach 1Our Labour Code of Conduct sets minimum labour standards safeguarding employee rights and ensuring consistent working conditions across global operations. We continuously assess the effectiveness of our Labour Code of Conduct. A global due diligence review covering a 5-year period was completed in 2025. It confirmed that our working condition standards are upheld and that a strong speak-up culture has been established, supported by multiple channels for reporting concerns. Employee compensation at Novo Nordisk exceeds local living wage standards (covering basic needs plus discretionary income) and is reviewed regularly to reflect changes in cost of living and economic conditions. Employees can apply for flexible work arrangements, such as career breaks, compressed work weeks, or reduced hours, with corresponding adjustments to pay and benefits. All employees are covered by social protection through public or company-provided benefits. Parental leave for non-birthing parents has been extended globally to 14 weeks paid leave. In Denmark and EU, working hours are monitored to support workâlife balance, in accordance with EU legislation. In markets where no laws or collective agreements apply, we aim to keep working hours under 48 hours per week. Novo Nordisk maintains policies to help ensure a workplace free from discrimination and harassment, based on both legal requirements and broader commitments to inclusion. The global Anti-Harassment Framework sets minimum process standards, implemented by local People & Organisation and Ethics & Compliance teams. In the US, these are supplemented by local frameworks. We ensure that workforce engagement takes place through direct dialogue and formal structures, such as our annual employee engagement survey Evolve. Employees have the right to organise and bargain collectively. Where legislation restricts these rights, we protect and support alternative representation and grievance mechanisms. In Denmark, five collective agreements are in place with elected employee representatives, and management meets union representatives quarterly. In Denmark and other EU countries, employees are represented through works councils or equivalent bodies. The European Works Council engages regularly, including an annual meeting of all representatives. These engagements support our assessment and continuous improvement of workforce practices, including target setting, implemented through local HR teams.1. The Labour Code of Conduct is aligned with the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the International Labour Organisations Declaration on Fundamental Principles and Rights at work and the Global Compact Ten Principles ActionsThe Novo Nordisk Way guided our actions throughout the transformation process, ensuring assistance for colleagues affected by the organisational changes e.g., by offering mental wellbeing resources and professional outplacement. Severance pay and other terms met local legal and market benchmarks, and a fair, transparent termination process across countries was prioritised. Employee representatives were engaged where required, and the European Works Council was informed and consulted during the process. PerformanceNovo Nordisk underwent a company-wide transformation in 2025, reducing the number of employees to 69,505 by year-end equal to 10% reduction when comparing to year-end 2024 including Catalent. The reorganisation in 2025 also impacted the number of leavers, increasing the employee turnover rate to 18.4%.13.1.1 Characteristics of Novo Nordiskâs employeesNumber2025 2024 2023268,794 73,109 63,370Total number of employees (FTEs)2Total number of employees (headcount)69,505 74,156 64,319⢠Men 35,453 37,416 â⢠Women 33,992 36,711 â⢠Other/ not reported 60 29 â3Country by country⢠EUCAN (Europe and Canada) 39,004 42,308 35,402⢠Hereof Denmark 29,613 34,185 28,692⢠USA 9,961 8,829 7,869⢠APAC (Japan, Korea, Oceania and Southeast Asia) 8,862 9,953 8,806⢠Region China (Mainland China, Hong Kong and Taiwan) 6,188 6,977 6,485⢠Emerging Markets (Latin America, the Middle East and Africa) 5,490 6,089 5,757Number of leavers 13,274 3,574 âEmployee turnover 18.4% 5.5% 5.5%1. All 2024 employee related metrics exclude Catalent. 2. 2024 figures: FTE and headcount are excluding Catalent. Including Catalent, FTE is 76,302 and headcount is 77,349. 3. Geographical split has been reorganised to align with the geographical regions applied throughout the Annual report. Hence 2024 and 2023 figures have been restated.Novo Nordiskâs HR systems currently provide employees the option to select their self-identified gender. Efforts are being made to raise awareness of this self-identification feature for future reporting, including other/not reported categories.By end of 2025, Novo Nordisk employed 64,974 permanent and 4,531 temporary employees, similar to the 2024 split (68,669 permanent and 5,487 temporary). No employees in Novo Nordiskâs own workforce are hired on non-guaranteed hours contracts.Through the Evolve survey we track overall engagement, the 2025 index score remained broadly stable year on year, with only a 1-point decline in favourable responses. Engagement remains high when benchmarked against external organisations. As the survey preceded the September 2025 reorganisation, any impact of this may be reflected in 2026 results. 3.1.2 Enterprise Evolve scoreFavorable % score 2025 2024 2023Enterprise Evolve score 84 85 86We have continued to advance our speak-up culture and anti-harassment framework as part of our company-wide campaigns to ensure awareness of speak-up channels, while recognising that some cases may not be reported to the Compliance Hotline. In 2025, the number of substantiated people-related cases increased by 5% compared to 2024. None of the cases were deemed as severe cases of human rights incidents. For substantiated cases, Novo Nordisk follows prescribed procedures to provide remediation. For more information about our grievance mechanism and non-retaliation policy, see section 9.2 on page 76.3.1.3 Incidents and complaintsNumber 2025 2024 2023Substantiated people-related cases175 167 â⢠Hereof substantiated cases of harassment, including 150 139 âdiscriminationAmount of material fines, penalties and compensation related â â âto the above-mentioned incidents (mDKK)3.2 Health and safetyPolicies and approachWe prioritise the health, safety and wellbeing of our workforce to ensure safe and reliable delivery of medicines. Our Global Health and Safety policy covers physical and psychological safety, occupational health and health promotion, with a strong focus on prevention, continuous improvement and regulatory compliance. The policy is implemented globally through a Health and Safety Management System, which addresses chemical and biological exposure, ergonomic hazards, noise, machine safety and psychosocial wellbeing. All production facilities are ISO 45001 certified with acquired sites being certified within a three year period and subject to regular internal and external audits. Leaders and employees are accountable, and safety is never compromised for cost or productivity. Health and safety principles are also embedded in expansion projects and construction sites, ensuring safe conditions throughout the value chain.ActionsHealth and safety actions are implemented in close collaboration with all business areas. Each area maintains a local plan addressing strategic risks and legal requirements, supported by global resources for remediation. An annual bottom-up review evaluates the effectiveness of the management system. In 2025, we sharpened our focus on preventing high-risk incidents, specifically those with Potential Serious Injuries and Fatalities (PSIF) and Serious Injuries and Fatalities (SIF). We are prioritising the identification, investigation and systematic prevention of PSIF/SIF, introducing a target to ensure that over 80% of PSIF/SIF incidents undergo systematic root cause analysis, in alignment with our Health & Safety policy. Formal performance monitoring against the new target will be initiated in 2026. To raise awareness and strengthen capabilities, we conducted intensive, targeted awareness training for key personnel and shared incident examples on a monthly basis. Integration of Health and Safety standards into acquired sites is ongoing, with full integration expected by 2027. One new site underwent internal health and safety audit, with remaining new sites scheduled for 2026â2027. Besides these ongoing actions, we have also implemented the following key actions in 2025:2025 actionsProtecting psychological safety⢠An enterprise-wide psychological safety concept was developed for all employees globally, with tools, frameworks, processes and awareness training in place.⢠In 2025, external vendors offering classes and workshops to support the psychological safety journey of employees were identified.⢠Metric: 3.2.1 (see table to the right) Executing safely on construction and expansion projects⢠Introduced a construction safety standard for high-risk activities identified in 2024 mapping, rolled out across major construction projects.⢠A 2025 gap analysis, supported by independent consultants, guided site improvements.⢠Metric: 3.2.1 (see table to the right)Targets and performanceWe have determined that our stable rate of LTIR is satisfactory following a benchmark against peers. As a result, we discontinued the year-on-year 10% improvement target for Lost Time Injury Rate (LTIR) in 2025. Instead, we have refocused our target on high-risk incident prevention to reduce incident frequency in the future. We will however continue to monitor LTIR. In 2025, the LTIR remained stable at 1.2 lost time injuries per million hours worked (ppm), even though the number of recordable work-related lost time injuries increased by 5%. The reason for the LTIR remaining stable is that the number of work-related lost time injuries was counteracted by average FTE also increasing in 2025 compared to 2024. The increase in number of work-related injuries reflects the continued production expansion and workforce growth prior to the transformation in September. Immediate corrective actions were launched following each injury. Stress symptoms and symptoms of physical pain are measured through our annual Evolve survey, which shows performance at a point in time. As the survey preceded the September 2025 reorganisation, any impact of this may be reflected in 2026 results. Evolve survey insights inform annual targets, with outcomes monitored continuously and reported annually.Stress symptoms were reported by 14.0% of employees, missing the 10% improvement target since 2024. Business areas with a high reporting of stress symptoms received customised interventions from internal organisational psychologists, leading to a 20% reduction in reported stress symptoms for these specific areas between 2024 and 2025. Work-related physical pain has declined, continuing last yearâs downward trend. However, the 5% reduction target was not fully achieved. 'Pain Awareness Workshops' in high-risk areas contributed to the improvement, though additional measures may be needed to meet future targets. 3.2.1 Health and safety (own employees)Number2025 2024 2023Recordable work-related lost time injuries 182 173 153Lost time injury rate (LTIR) (ppm) 1.2 1.2 1.3Fatalities as result of work-related lost time injuries, incl. other workers working on Novo Nordisk sites 0 0 1Employees reporting symptoms of stress14.0% 13.8% 13.8%Employees reporting symptoms of work-related physical pain6.7% 6.8% 7.1%Workforce (headcount) covered by health and safety management system100% 100% â3.3 Equal treatment and opportunities for allPolicies and approachNovo Nordisk strives to build a diverse and inclusive workplace that leverages differences, fosters learning and growth and drives innovation. We recognise that diversity is any dimension that differentiates our people and enables diverse thinking, for example gender, ethnicity, race, nationality, disability and sexual orientation. Our Diversity and Inclusion policy supports our organisation as reflective of our patients and customers and society at large. We focus on mitigating bias by creating inclusive workplaces and ensuring leaders act as role models. Equality is applied to all stages of employment, including recruitment, remuneration and promotion in line with all local laws and regulations in the jurisdictions in which we operate. Input from employees, leadership and peers ensures that our Diversity, Equity, Inclusion and Belonging efforts reflect workforce needs and societal expectations. To foster a workplace where everyone can meaningfully participate, perform their best and to build a strong talent pipeline, we cultivate belonging by leveraging the diverse skill sets, knowledge and experience of our employees. Promoting equal opportunities also means creating a strong learning culture. Personal and professional growth is ensured through ongoing development dialogues and documented development plans. These plans focus on both short-term goals and long-term career aspirations and are structured to focus on both learning experiences and formal training. While we have no standalone training policy, we apply compliance-driven and job-specific training procedures.ActionsA new Global Diversity, Equity, Inclusion and Belonging strategy has been launched to leverage differences, adapt to changes and foster an engaged workforce that drives innovation for patients. We continue to assess how to improve learning and career advancement opportunities for our employees. At a minimum, we provide access to self-directed learning content, opportunities for internal mentors and coaches and advertise short-term developmental job rotations for all employees. In response to the transformation, we paused all global talent, leadership and learning programmes in Q4 2025 to evaluate and realign them with our strategic priorities. Our updated learning and development portfolio will be launched in Q1 2026 to deliver the capabilities needed for the future. We perform equal pay reviews to ensure that individuals with similar roles and responsibilities are compensated equitably, regardless of background, gender, or ethnicity to safeguard equal and fair pay. This process covers global operations, excluding US and Canada, which follows its own processes. Alongside the equal pay review process, Novo Nordisk has enhanced transparency of reward elements, including salary ranges, short-term incentives, benefits, and long-term incentives. Employees can now access their own salary positioning. These measures aim to minimise bias and support fair and equal pay.2. The previously stated minimum 45% gender split is no longer a target but an aspirational objective.Performance2In 2021, we defined two global aspirations: one for balanced gender representation at all managerial levels, and one aiming for at least 45% women and 45% men in senior leadership (VP+) by the end of 2025. The aspirations, covering Novo Nordisk A/S, excluding the US, was benchmarked against peers, leading Danish companies, industry standards and academic research. They were developed with executive input, approved by the Board and have been transparently monitored. In 2025, women occupied 47% of all leadership positions and men occupied 53%, consistent with 2024 figures and thereby meeting our aspiration for balanced gender distribution across all managerial levels (see table 3.3.3 on the following page). At the senior leadership level, 44% of roles were held by women and 56% were held by men at the end of 2025 (see graph 3.3.2 to the right). Despite the 2% point change since 2024, the aspiration for senior leadership was not met by the December 2025 deadline. We will continue to monitor the gender distribution across senior leadership levels. Across all of our efforts, we monitor our global inclusion index, which is part of our annual employee engagement survey, Evolve. It indicates how our employees rate the state of inclusion at Novo Nordisk, and it resulted in 80% of our employees rating the inclusion statements favourably in 2025.As of 31 December 2025, the Board of Directors (BoD) had equal gender representation with four women and five men (as of 31 January 2026, the BoD consists of five women and four men). Excluding employee representatives, shareholder-elected members included one woman and four men, not meeting the Danish Gender Balance Act. Novo Nordisk remains committed to achieving balanced gender representation on the BoD in line with applicable legislation. For details on how this will be ensured and how diversity is considered during candidate evaluation, see the section on 'Gender Balance Act' on page 61 and the Corporate Governance Report. In 2025 we have refined our methodology on the gender pay gap to present the weighted gender pay gap across all job levels and countries. The weighted gender pay gap considers geographical differences, but it does not take into account job level variances. This adjustment is intended to further enhance transparency around our compensation practices. In 2025, the gender pay gap is 1.2% in favour of women. The remuneration ratio was impacted by a lower payout on the short-term incentive programme for 2025, and a lower performance on the long-term incentive programme for 2025. 3.3.1 Remuneration metrics 2025 2024 20231Gender pay gap(1.2%) (0.4%) â2Annual total remuneration ratio37 63 â1. 2024 figure for Gender pay gap has been restated from (3)% due to a methodological change. 2. Based on present CEO as highest paid employee. If calculated based on former CEO's remuneration, the ratio would be 148 due to severance payment in 2025. 3.3.3 Diversity metrics â Management levels Men Women Number 2025 2024 2023 2025 2024 20231Number of employees (headcount) at senior leadership â CEO, EVP, SVP, GVP and VP491 504 â 379 361 âPercentage of employees (headcount) at senior leadership â CEO, EVP, SVP, GVP and VP 56% 58% 59% 44% 42% 41%Number of employees (headcount) at other leadership levels â Director, manager, team leader 4,598 4,726 â 4,075 4,171 âPercentage of employees (headcount) at other leadership levels â Director, manager, team leader 53% 53% 54% 47% 47% 46%Gender in leadership positions (overall) 53% 54% 54% 47% 46% 46%Gender on the Board of Directors 56% 50% 50% 44% 50% 50%Gender on the Board of Directors without employee representatives 80% 62% 62% 20% 38% 38%1. Historical data for Number of employees (headcount) at senior leadership level has been merged into one row instead of two in last yearâs reporting. This has not impacted the reported number (headcount) at senior leadership level. Gender Balance Act - Applicable for Novo Nordisk A/S onlyNovo Nordisk A/S, as resident in Denmark, is subject to the Danish Gender Balance Act and obliged to disclose information on gender diversity in the Board of Directors and other management levels for employees employed in Novo Nordisk A/S. Other management levels are defined as two levels of management under the Board of Directors: (i) Executive Management (EVPs employed by Novo Nordisk A/S), and (ii) individuals with personnel responsibility who report directly to the first 1management level. Hence, Other management levels are not equal to senior leadership levels. Measures taken to achieve gender balance When evaluating candidates for election and re-election for the shareholder-elected Board members, the People & Governance Committee and the Board considers the Competency Profile of the Board of Directors of Novo Nordisk A/S which includes diversity in terms of e.g., gender and other relevant criteria. In regards to employee representatives, Novo Nordisk A/S has employee representation in its Board of Directors and promotes the election to all eligible employees regardless of backgrounds.For selecting employees at Other management levels, Novo Nordisk A/S ensures a strong leadership pipeline of diverse talents through its commitment to promoting equality of opportunities within Novo Nordisk A/S. Status on achieving gender balance Novo Nordisk A/S has achieved gender balance as defined in the Danish Gender Balance Actfor employee representatives in the Board of Directors and in Other management levels, however, it has not achieved gender balance for Board of Directors elected by shareholders.1. For other management levels, the reporting only regards employees of Novo Nordisk A/S.2. Ratio as of 31 December 2025. As of 31 January 2026, all employee representatives are women. ACCOUNTING POLICIES Enterprise Evolve score Measures the average percentage of favourable answers to the 18 engagement items shared in Novo Nordiskâs annual employee survey. Favourable answers are defined as 'Agree' and 'Strongly agree' to positively framed questions. The survey is performed once per year in the spring administered by an external vendor. Employees (headcount)Measured as the headcount of all employees at year-end, excluding externals, employees on unpaid leave, interns, Bachelorâs and Masterâs thesis employees and substitutes. Employee data are based on registrations in Novo Nordiskâs HR systems. Employees are attributed to geographical regions according to their primary workplace.Number of leaversThe number of employees (headcount), excluding temporary employees, who left the Novo Nordisk Group during the year. Employee turnoverMeasured as the number of leavers during the financial year, divided by the average number of employees (headcount), excluding temporary employees. Substantiated people-related casesCases that, through a formal process, have been reported to or filed with the Compliance Hotline and have been substantiated or partially substantiated based on an investigation during the year (partially substantiated: an allegation encompasses several aspects, but only a subset of them can be confirmed). Cases are within the overarching categories of the global anti-harassment framework, the Novo Nordisk Way and Ombudsman, as well as other potential human rights breaches for internal employees, consultants and other externally hired individual workers.Substantiated cases of harassment, including discriminationCases that have been closed as substantiated or partially substantiated based on an investigation under the Novo Nordisk Way and the global anti-harassment framework for our own workforce (partially substantiated: an allegation encompasses several aspects, but only a subset of them can be confirmed).Amount of material fines, penalties and compensation related to the above-mentioned incidents Damages resulting from violations of social or human rights laws, including discrimination and severe human rights incidents, where a Novo Nordisk legal entity (parent or affiliate) has been found in violation by a court of law and been condemned to pay material fines, penalties or compensation. Recordable work-related lost time injuriesTotal number of work-related incidents causing absence for one full day or more, in addition to the day of incident. Absence is considered as calendar days. Lost time injury rate (LTIR)Rate of recordable work-related injuries for our own workforce, measured in work-related injuries per million hours worked, also referred to as the lost-time accident frequency (LTAF). Contractors, visitors, employees on unpaid leave, interns and Bachelorâs and Masterâs thesis students are not included. The number of hours worked is based on 2,000 working hours annually per full-time equivalent and the monthly records of number of employees converted into full-time equivalents to calculate FTE average for the year. Fatalities as a result of work-related lost time injuriesWork-related injuries resulting in the death of an employee or other workers working on a Novo Nordisk site. All employees (headcount), permanent, temporary and non-guaranteed hours, have been included in this metric. Percentages of employees reporting symptoms of stress/work-related physical pain Reported via the annual employee survey Evolve. In 2025, the scope of the survey was extended to a few Catalent entities acquired in late 2024. In the survey, stress is defined as a situation where the employee feels tense, restless, nervous or troubled, or unable to sleep at night due to thoughts about their problems. Regarding symptoms of physical pain, the survey asks if an employeeâs work generally causes them physical pain. The two relative targets of improving mental and physical wellbeing are measured as the percentage of employees responding 'Quite much' or 'Very much' for mental wellbeing or 'Unfavourable' to the statement related to physical pain.Workforce covered by health and safety management system (headcount) The percentage of employees in Novo Nordiskâs own workforce who are covered by our health and safety management system based on legal requirements and/or recognised standards or guidelines is defined as the number of employees covered by health and safety management systems (headcount) divided by all employees (headcount). Gender pay gap Calculated as the difference between the weighted average annualised salary for men and women divided by the weighted average annualised salary of men and expressed as the percentage of the average annualised salary of men. All employees at all job levels and in all countries have been included in this metric. Annual total remuneration ratio Calculated as the ratio between the annual remuneration of the highest paid individual (the present CEO) and the average annual remuneration for all employees excluding registered executives. Payments include salary, incentive schemes and severance payments if applicable. Gender in leadership and senior leadership positionsReported as the percentage of gender in leadership and senior leadership positions. Senior leadership positions are defined as employees in the global job levels chief executive officer (CEO), executive vice president (EVP), senior vice president (SVP), group vice president (GVP) and vice president (VP). These are the top management positions in the Novo Nordisk Group. Other leadership levels are defined as employees in the global job levels of director, manager and team leader. Leadership positions overall are defined as directors, managers, team leaders and senior leadership positions. Diversity on the Board of Directors is reported as the percentage split by gender among all members, including employee elected members.PrioritisedtopicsPatient protection and quality of lifeOwn workforceClimate ChangeResource use and circular economyAmbitionWe aim to build a climate-resilient business by assessing and adapting to climate risks, reducing GHG emissions in line with a well-below 2°C pathway, and transparently reporting across our value chain under the GHG Protocol.PolicyEnvironmental policyPerformance⢠Scope 1, 2 and 3 emissions increased 19% since 2024Suppliers for Zero Programme⢠In 2025, we launched the Suppliers for Zero programme to align suppliers with our climate, nature and plastics goals. ⢠All Tier 1 suppliers must source 100% renewable electricity by 2033. ⢠Suppliers must also meet our Responsible Sourcing Standards⢠Additional initiatives will be defined by Novo Nordisk in individual engagements.4. Climate changeIRO name Category Sustainability topic Value chain locationCO2e emissions contributing to ⢠Mitigation⢠Upstreamclimate change⢠Energy⢠Own operations⢠DownstreamPotential reputational risks linked to ⢠Mitigation⢠UpstreamCO2e emissions and speed of ⢠Energy⢠Own operationsmitigation efforts⢠DownstreamPotential risks of climate-related ⢠Adaptation ⢠Upstreamdisruptions in operations or supply ⢠Own operationschain⢠DownstreamMaterial impacts, risks and opportunitiesAs a global pharmaceutical company, we recognise that our activities, from sourcing raw materials to manufacturing and distribution, have a material climate impact. As we expand, so does the impact unless we take deliberate action to change it. The majority of our GHG emissions (93%) arise upstream and downstream in our value chain.This includes emissions from sourcing of raw materials and services (direct), other goods and services (indirect) for medicine production, the construction of new manufacturing facilities (investments) and the distribution of raw materials and finished products. Direct operational emissions (scope 1 and 2) represent only 7%. We acknowledge that until we fully decouple business growth from emissions, our operations will continue to generate negative environmental impacts and expose us to transition and reputational risks. We are actively advancing decarbonisation and adaptation plans to strengthen resilience and progress our climate roadmap.4.1 Climate mitigation, adaptation and energyPolicies and approach The Novo Nordisk Environmental policy affirms our commitment to providing life-changing treatments for people with serious chronic diseases while minimising environmental impact. Pharmaceutical production, from producing APIs and excipients to manufacturing, packaging, cold-chain distribution and end-of-life handling, has a material climate footprint. We are committed to achieving our COâe emission reduction targets through energy efficiency, renewable energy, process optimisation and other decarbonisation levers (see illustration 4.1.2), while systematically assessing and adapting to climate-related risks. The policy covers all our activities globally and is embedded across the pharmaceutical value chain. Implementation is led by management teams and supported by on-site environmental partners at all production facilities, ensuring compliance and continuous improvement. Production sites are ISO 14001 certified for environmental management (excluding all new acquisitions and construction projects) and our Kalundborg site is also certified according to ISO 50001, energy management. Our ISO 14001 is linked to our Circular for Zero Factory Model, which assists manufacturing sites to identify strategic maturity level in line with Novo Nordiskâs environmental roadmaps: climate, nature and plastics, while also driving actions throughout our Environmental Management System.Transition- and physical climate risks assessmentWe assess transition and physical climate risks through our Enterprise Risk Management (ERM) framework across our production, including the sourcing of APIs, excipients, packaging and logistics. In 2024, we conducted a forward looking climate resilience analysis using 1.5 °C (RCP 2.6) and 4 °C (RCP 8.5) scenarios from the IPCC towards 2030 and 2050, which assume economic constraints arising from moderate population and GDP growth. These scenarios were selected to reflect both 'business as usual' as well as rapid decarbonisation pathways and their impact on our activities. Short-, medium- and long-term risks were evaluated and scenario outcomes are used to inform strategic decisions on site resilience, supply chain planning and our decarbonisation roadmap.The physical risk assessment focused on site exposure and critical raw materials. Physical climate risks are screened annually at production sites (excluding warehouses) and in parts of the supply chain. For production sites, we assess risks based on geographic location, while for supply chain assessments we consider supplier countries. The transition risks assessment was evaluated using an Integrated Assessment Model (IAM) to capture sector- and region-specific macroeconomic shifts, energy supply, raw materials pricing, labour costs and revenue changes. We assess and adjust mitigation measures, where feasible based on parameters such as evolving national policies, availability of low carbon technologies, energy supply conditions, thereby increasing business resilience to climate risks. No aspects of our business were identified as incompatible with a transition to climate-neutral economy.Annual % 4.1.1 Scope 1, 2 and 3 GHG emissions targets (target/12e 20242025 2030 2033 2045base)1,000 tCOScope 1 and 2 GHG emissions - market-based 101 183 0 0 0 17%2 (SBTi) 1,448 1,616 â 970 03Scope 3 GHG emissions4%Scope 3 GHG emissions (excluded from SBTi target) 712 891 Not applicableScope 3 GHG emissions 2,160 2,5071.Base year 2. Following the target validation by SBTi in 2025, we revised base-year emissions from 1,493 to 1,448. 3. Net emissions with residual emissions after the decarbonisation levers (150 thousand tCO2e) to be neutralized through carbon removals.Climate targets and transition planNovo Nordisk has three targets for climate as outlined in the margin to the right and summarised in table 4.1.1: 2030 target for scope 1 and 2, 2033 target for scope 3 (2033) and a 2045 net-zero target for scope 1, 2 and 3. Our transition plan and decarbonisation leversOur transition plan is aligned with our climate targets and our strategic priorities, and is based on projected growth in production volumes and expansion projects. It takes into account several uncertainties and assumptions, such as business growth projections to reflect the increased resource use in the coming years and the reduction potential of available technologies. The plan addresses both transition pathways for our direct operations (scope 1 and 2) and our value chain (scope 3). Emissions reduction efforts in our own operations are focused on switching to renewable energy, increased energy efficiency and transition to electric vehicles (EV). For scope 3 emissions, our transition plan relies on a portfolio of low-carbon value chain initiatives, and we will further focus on our suppliersâ transition to renewable electricity as well as process optimisation to reduce overall demand for materials and services and optimise our processes even further.Our main decarbonisation levers are (as outlined in 4.1.2):⢠Direct spend: Procurement of low-carbon feedstocks for key raw materials, such as e-methanol for plastic devices, low-carbon ammonia and glucose from regenerative agriculture;⢠Indirect spend: Procurement of low-carbon goods and services;⢠Investments: Converting to low-carbon construction materials;⢠Distribution: Converting product distribution from air freight to sea- and road freight, while sourcing Sustainable Aviation (SAF) and Marine Fuels (SMF) and converting to electric trucks;Assumptions and uncertaintiesWe recalibrate priority areas continuously. Although some scope 3 decarbonisation levers are already implemented to mitigate projected emission increase, many of our levers have a delayed effect and will not materialise until 2030. Overall emissions are therefore expected to keep increasing before reductions take effect towards 2033. This reflects planned expansion and the timing of decarbonisation measures, not a deviation from our transition pathway. Progress against targets is monitored through interim milestones to ensure alignment with our transition plan. We acknowledge that going forward we will need to explore other initiatives to address unallocated opportunities. Beyond 2033, we will continue to work with our value chain initiatives and we plan to neutralise up to 10% of baseline emissions through carbon removals to meet our 2045 net-zero target, in line with SBTi and IPCC guidance. We are exploring both nature-based and technology-based removal solutions. Read more about our restoration efforts in section 7 'Nature' p. 72.Targets within transition plan ⢠2030: Zero scope 1 and 2 emissions.⢠Ambition: 1.5°C aligned1⢠2033: 33% reduction in scope 3emissions compared with 2024 baseline.⢠Ambition: Well-below 2°C, not 1.5°C aligned⢠2045: Net-zero emissions, ⢠Ambition: Aligned with the Corporate Net-Zero Standard1. Our 2033 scope 3 target covers ~67% of emissions, excluding categories 3, 5, 7, 12 and parts of 1, 2 and 6, in line with SBTi provisions for high-uncertainty categories. The target follows a sectoral decarbonisation pathway. The 2045 net-zero target includes all scope 1, 2 and 3 emissions. The targets and the transition plan have been approved by our Board of Directors and Executive Management.ActionsMany of our 2025 actions addressed our aim to decarbonise own operations. We have worked with initiatives to reduce energy consumption through optimising sites and processes and we started to develop site-specific conversion plans for fossil-based heat and steam systems. To reduce emissions across our value chain we increased the number of suppliers committed to renewable electricity (see margin to the right) and we successfully implemented initiatives with several of our key suppliers in the highest-impact sourcing categories.Besides these ongoing actions, we have also implemented the following key actions in 2025:2025 actions Scope 1 and 2: Energy efficiency and optimisation, ongoing to 2030. ⢠Advanced district cooling and heating ring in Kalundborg (completion 2026, ~20,000 MWh/yearly savings) and new heat pump in Hillerød completed in 2025 (~3,300 MWh/yearly savings).⢠Target: Zero scope 1 and 2 by 2030, Metric: 4.1.4Scope 1 and 2: Converting to renewable heat and steam, ongoing to 2030. ⢠Investigating heat and steam decarbonisation levers across production sites to enable cost-efficient implementation. Specific roadmap to be finalized in 2026. ⢠Target: Zero scope 1 and 2 by 2030, Metric: 4.1.4Scope 1 and 2: Reducing emissions from fossil-based vehicles, ongoing to 2030. ⢠Expanding EV transition in alignment with local infrastructure across operational countries. ⢠Target: Zero scope 1 and 2 by 2030, Metric: 4.1.4Scope 3: Reducing emissions from purchased good and services, until 2033 and beyond.⢠Partnering with suppliers on low-carbon materials and feedstocks: first large-scale e-methanol project in Kassø for e-POM production. ⢠In 2025, over 10% of the glucose we procured was from regenerative agriculture and a large share of purchased ammonia was low-carbon.⢠Converting to low-carbon (e.g., steel, concrete) and recycled materials at site Clayton.⢠Target: Reduce scope 3 by 33% by 2033, Metric: 4.1.4Scope 3: Reducing emissions from air and sea distribution, to 2033 and beyond. ⢠Securing sustainable aviation fuel (SAF) and marine fuel (SMF) agreements with logistics partners.⢠Target: Reduce scope 3 by 33% by 2033, Metric: 4.1.4Climate adaptation to address physical climate risks, until 2033 and beyond⢠In 2025, natural hazard exposure reassessed for all production sites and critical suppliers, with detailed climate and nature risk evaluations for key commodities. The analysis indicated 5 key commodities that could potentially be impacted by climate change.Performance Total energy consumption increased by 23% compared to 2024, mainly due to the integration of electricity and natural gas consumption at acquired production sites. These acquisitions accounted for over 80% of the energy consumption increase at production sites, while our construction and expansion activities played only a minor role in the overall increase. In 2025, we refined our reporting methodology to better distinguish between renewable and non-renewable steam and heat, and we now include contractual biomass-derived sources in Kalundborg, Denmark, under renewable energy (both for 2024 and 2025). Otherwise, we continue to adopt a conservative approach with only including energy as renewable, if suppliers have contractual agreements in place. In 2024, renewables, mainly electricity, biogas and biomass-based heat and steam, accounted for 66% of total energy use, but declined to 57% in 2025 due to the increase in fossil energy consumption in our recent acquisitions. Specifically, the share of renewable electricity for production sites dropped from 100% in 2024 to 86% in 2025, driven by the acquisition of new sites without renewable electricity setup. We have also started to measure and report on self-generated renewable electricity in 2025.In 2025, the total amount of energy savings achieved through our energy saving initiatives increased from 13.7GWh in 2024 to 29.8 GWh. Yet, this reduction could not offset the overall growth in energy consumption. 4.1.3 Energy consumption and mix GWh 2025 2024 2023Total energy consumption related to own operations 1,726 1,400 1,051Total energy consumption from fossil sources 742 476 â⢠Fuel consumption from crude oil and petroleum products 169 188 â⢠Fuel consumption from natural gas 369 196 â⢠Consumption of purchased or acquired electricity, heat, steam, 2204 92 âand coolingTotal energy consumption from renewable sources 984 924 â⢠Fuel consumption from renewable sources 156 154 â⢠Consumption of purchased or acquired electricity, heat, steam 2827 770 âand cooling from renewable sources⢠Total self-generated non-fuel renewable energy 1 0 âPercentage of fossil sources in total energy consumption 43% 34% â1Percentage of renewable sources in total energy consumption57% 66% â2Energy intensity (total energy consumption per net revenue) 5.58 4.82 â(MWh/mDKK)1. Contractual biomass-derived heat and steam is included under renewable sources in 2025 and the 2024 values were restated from 54% to 66%, 46% to 34%. Accordingly, the values for consumption of fossil-based electricity heat and steam was restated from 264 GWh to 92 GWh in 2024 and consumption of renewable electricity, heat and steam was restated from 599, GWh to 770 GWh. 2. Please see note 2.1 'Net sales and rebates' on page 88 in the Consolidated financial statements. Suppliers for Zero ProgramTo reach our scope 3 targets, we need our suppliers and CMOs to implement specific decarbonisation levers and support us to improve data foundations to measure impacts and potentials.We provide support to our suppliers through collaborative partnerships and free training% of GHG emissions from suppliers who have committed to sourcing renewable 1electricity54%41% in 20241. Commitments cover electricity consumption from suppliers to Novo Nordisk within scope 3 category 1 and 2.4.1.4 Scope 1, 2 and 3 GHG emissions% change 1,000 tCO2e 2025 2024 2023(2025/2024)Scope 1 GHG emissions 120 85 78 41%Scope 2 GHG emissions - market-based 63 16 15 294%Scope 2 GHG emissions - location-based 198 174 â14%Scope 1 and 2 GHG emissions - market-based 183 101 93 81%Scope 3 GHG emissions 2,507 2,160 1,743 16%⢠Category 1: Purchased goods and Services 1,383 1,215 1,018 14%⢠Category 2: Capital goods 609 465 303 31%⢠Category 3: Fuel- and energy-related activities 86 74 56 16%⢠Category 4: Upstream transportation and distribution 116 101 108 15%⢠Category 5: Waste generated in operations 7 6 6 17%⢠Category 6: Business travel 190 188 154 1%⢠Category 7: Employee commuting 56 52 43 8%⢠Category 9: Downstream transportation and 57 57 52 0%distribution⢠Category 12: End-of-life treatment of sold products 3 2 3 50%Total GHG emissions - market-based 2,690 2,261 1,836 19%Total GHG emissions - location-based 2,825 2,419 â 17%GHG emissions intensity, market-based (total GHG 1emissions per net revenue) (tCO2e/mDKK) 8.7 7.8 â 12%GHG emissions outside of scope 1 and 2 (1,000 tCO2) 108 110 â(2%)⢠Biogenic emissions (scope 1) 38 37 â 3%⢠Biogenic emissions (scope 2) 70 73 â (4%)1. Please see note 2.1 'Net sales and rebates' on p. 88 in the Consolidated financial statements. Performance Scope 1, 2 and 3 GHG emissions increased, as anticipated (see graph 4.1.5 to the right). Therefore we did not achieve any emission reductions in 2025. Scope 1 emissions (see table 4.1.4 to the left) increased by 41% from 2024 to 2025 primarily due to an overall increased use of fossil natural gas. The five acquired sites accounted for the majority of the increase in scope 1 emissions. Even though total scope 1 emissions increased, scope 1 emissions related to the consumption of diesel as well as gasoline declined in 2025, in line with our aim to reduce emissions from fossil-based vehicles. Scope 2 (market-based) emissions increased by 294% from 2024 to 2025, driven by non-renewable electricity use at three of the acquired production sites. Our ambition is to transition to long-term renewable solutions that add new renewable capacity to the grid, rather than relying on standalone certificates. This means acquisitions may have an adverse effect on the renewable share before long-term solutions are implemented. Besides the growth in non-renewable electricity consumption at the acquired sites, non-renewable steam consumption at our site expansion in China was also another contributing factor to the increase in scope 2 emissions. Scope 3 emissions increased by 16% from 2024 to 2025, driven by both procurement of goods and services (category 1) and higher CapEx for property, plant and equipment (category 2). Categories 1 and 2 made up nearly 80% of total scope 3. Purchased goods and services (category 1) continue to be the largest scope 3 emissions source. In 2025, the biggest increase in category 1 came from service-related activities, followed by overall increase in the procurement of production materials and services. To address this challenge, we have in 2025 started to source low-carbon materials and increased the share of our suppliers sourcing renewable electricity (see margin on preceding page). As anticipated, the fastest growth in scope 3 emissions was reported in category 2, where our construction and expansion activities were the single largest driver of the total growth. To address this challenge, we focused our efforts in 2025 to foster circularity in the construction of new sites, by setting new thresholds for building design and material choice, and implementing a new standard to design sites for deconstruction and adaptability. For details, see the Action table in section 5.1 'Resource use and circular economy'). Decarbonisation efforts in category 4 (Distribution) were challenged by company growth and increased by 15% compared to 2024. Supply chain optimisation as well as procurement of sustainable aviation fuel (SAF) and sustainable marine fuel (SMF) were not able to fully offset this growth. Category 6 (Business travel), on the other hand, remained stable compared to 2024, reflecting the reduction in employee travel in the second half of the year following the business transformation. Other scope 3 categories remained similar to the 2024 levels.ACCOUNTING POLICIES Total energy consumption from fossil sources under Novo Nordisk controlPrimary energy consumption from coal, crude oil, petroleum products and natural gas, as well as consumption of externally purchased secondary non-renewable energy such as electricity, heat, steam and cooling. Energy consumption is based on meter readings and/or invoices. Total energy consumption from renewable sourcesPrimary energy consumption from renewable fuels (wood, biogas, bioethanol and biodiesel); as well as externally purchased and self-generated renewable electricity and biomass-derived heat and steam, as defined in the contractual agreements. Consumption is based on meter readings and/or invoices and complemented with contractual agreements.Energy intensity/GHG intensity Total energy consumption/total GHG emissions per net revenue. For energy intensity this corresponds to energy intensity from activities in high climate impact sectors. It is assumed that all activities of the Novo Nordisk Group are in a high climate impact sector (NACE code C21). Net revenue refers to total net sales generated by Novo Nordisk.The reporting of GHG emissions follows the ESRS and GHG Protocol. All impact is measured in tonnes of CO2e; using the Global Warming Potential (GWP) values published by the IPCC based on a 100-year time horizon and includes emissions of CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3. Scope 1 GHG emissions Scope 1 includes CO2e emissions from fuels used in stationary installations on site and mobile installations, as well as fugitive emissions of refrigerants. Emission factors for the respective energy types are based on the UK Government GHG Conversion Factors for Company Reporting. N2O and CH4emissions from the consumption of biofuels are included in scope 1 and 2, while bio-based COâ emission are assumed to be zero and are not included but disclosed separately under biogenic emissions. GHG removals, carbon credits and avoided emissions are not included.Scope 2 emissions Indirect GHG emissions from electricity, heat and steam, purchased and consumed by Novo Nordisk. Location-based emissions are calculated using grid average emission factors on local/regional/national level. Market-based scope 2 emissions are calculated taking into account contractual instruments such as Energy Attribute Certificates, Power Purchase Agreements and Guarantees of Origin from sources such as wind, hydro, solar and biomass. For sites without such contractual agreements, residual mix emission factors are applied when available, alternatively the grid average emission factor. For steam and district heating, the market-based scope 2 emissions are calculated using supplier specific emission factors. In general, sources of emission factors for scope 2 emission calculations include IEA, AIB, Green-e and supplier specific factors. Biogenic emissions refer to out of scope emissions of CO2 from the combustion of biomass-based primary fuels (scope 1) and biomass-derived electricity, steam and district heating (scope 2). Biogenic emissions from our fermentation process are not included due to high calculation uncertainty.Scope 3 emissions Indirect GHG emissions that originate from our value chain. Novo Nordisk has identified nine categories of scope 3 emissions out of the fifteen defined by the GHG Protocol as significant. The remaining six categories are not reported on separately, as they are not applicable to Novo Nordisk. Accounting policies are detailed only for the two most material categories of scope 3 â category 1 and 2. Our calculation methods for remaining categories 3, 4, 5, 6, 7, 9 and 12 are in line with the GHG Protocol and include the supplier-specific method, distance-based approach, average-activity method, average spend-based method and other hybrid methods.In general, major sources of emission factors include EPA, DEFRA, EXIOBASE, GaBi and other industry databases and standards. We continuously strengthen scope 3 reporting to improve accuracy, track action levers and reflect progress as low-carbon materials are introduced. Our goal is to use supplier-specific emission factors for much of scope 3 reporting. Given limited data availability and evolving science, future restatements remain plausible.Category 1: Purchased goods and servicesPurchased goods and services include purchased raw materials, packaging materials and consumables, as well as services such as marketing, IT and facility services. If available, direct spend is converted into CO2e emissions using the average activity data method where material weights are matched with CO2e factors. A spend-based factor is applied for other direct spend data where no weight can be obtained. Indirect spend is converted into CO2e using a spend-based method. Category 2: Capital goodsCapital goods include emissions related to all indirect investment spend from external suppliers, mainly production utilities and equipment. Indirect spend is converted into CO2e emissions via the average spend-based method using emission factors.PrioritisedtopicsPatient protection and quality of lifeOwn workforceClimate ChangeResource use and circular economyAmbitionWe aim to reduce our plastic footprint by extending the life of materials beyond patient use and minimising plastic through smarter design, reusable solutions, optimised processes and sustainable alternatives.PolicyEnvironmental policyPerformance⢠Plastic footprint per patient decreased 5% since 2024Plastic roadmap1. Reduce by converting to reusable devices and less frequent dosing2. Change by transitioning to non-virgin-fossil plasticTM3. Avoid by expanding the ReMedtake-back programme5. Resource use and circular economyIRO name Category Sustainability topic Value chain locationResource use associated with ⢠Resource inflow ⢠Upstreammanufacturing and capacity ⢠Own operationsexpansionsEnd-of-life waste from products ⢠Resource outflow⢠Own operations⢠DownstreamResource waste associated with ⢠Waste⢠Own operationsmanufacturing⢠DownstreamPotential reputational risks ⢠Resource inflow⢠Upstreamassociated with resource use⢠Resource outflow⢠Own operations⢠Waste⢠DownstreamMaterial impacts, risks and opportunities At the core of our Circular for Zero strategy is a commitment to decouple resource use and waste from our ability to serve growing number of patients. Novo Nordisk depends on resource inflows such as plastics, glucose, solvents and packaging to produce medicines and devices, and construction materials to expand manufacturing. Environmental impacts occur across our operations and value chain, such as at product end-of-life, where limited recycling options for pharmaceuticals lead to incineration or landfill, e.g., plastic device waste. Production waste is another key impact, where most waste is sent for recycling and landfill is minimised. We also recognise reputational risks tied to resource consumption that arise mainly in connection with the production of our devices. 5.1 Resource inflow, outflow and wastePolicies and approachCircularity is anchored in our Environmental policy, which states our commitment to designing out waste and pollution and keeping materials in loops. Our Environmental policy outlines our commitment to promoting low impact products and processes, when possible, for example by finding ways to use waste from one process as a resource in another process. We also strive to source reused, recycled and renewable materials, while always considering patient safety and the stringent regulatory requirements applicable to the pharmaceutical sector. The processes to assess impacts and risks involves annual environmental assessments at our production sites and within product development processes.We systematically use third-party-validated LCAâs (Life Cycle Assessments) to understand and reduce product impacts. We prioritise waste avoidance and reduction over waste treatment and address all levels of the waste hierarchy, from prevention and reuse to recycling, energy recovery and disposal. For details on chemical and water management, see section 8 'Pollution' and section 7 'Nature'. ActionsWe focus on plastics and production waste, guided by our target to reduce the plastic footprint per patient with 30% by 2033 compared to 2024. Ongoing actions include initiatives such as recycling of ethanol in our production, applying Circular Design Guidelines and innovating ®treatment methods that reduce the plastic footprint (e.g., with Awiqli). To further address waste TMfrom our own products, we have a take-back and recycling scheme called ReMed. As of the end of 2025, the scheme is scaled up to the national level in Denmark and the UK, while in other countries (Brazil, France, Italy, Japan and Germany) it is currently available in selected geographic areas. We also work to enhance packaging circularity for the future. To address waste associated with production, we continuously work to eliminate landfill waste from our production sites globally by diverting waste to incineration with energy recovery, other recovery operations or recycling. Besides these ongoing actions, we have also implemented the following key actions in 2025 (see next page):2025 actionsConvert to lower-carbon plastics (non-virgin-fossil alternatives with a lower carbon footprint) in our medical devices globally by 2033.⢠In 2025, first large-scale e-methanol project in Kassø (DK) inaugurated for e-POM production.⢠Target: Reduce scope 3 CO2e emissions by 33% by 2033, Metric: 4.1.4Fostering circularity in construction of new sites towards 2033.⢠In 2025, new LCA thresholds launched to drive sustainable building design and material choices.⢠In 2025, new standard introduced for designing sites for deconstruction and adaptability, promoting long-term reuse and procurement of more sustainable or recycled materials.⢠For our expansion at site Clayton (USA), approximately 46% of civil, architectural and structural (CSA) materials procured are classified as more sustainable (bio-based, FSC-certified wood, or recycled content); the target for circularity in expansions is to reach 50%..⢠Target: Reduce scope 3 CO2e emissions by 33% by 2033, Metric: 4.1.4Converting to reusable devices by 2033 to treat more patients with reusable devices.⢠In 2025, we worked on preparing a cost-efficient reusable injection pen for launch.⢠Target: Reduce our plastic footprint per patient by 30% by 2033.⢠Metric: 5.1.3 Plastic footprint per patient (kg/patient).Innovating treatment methods by 2033 ®⢠Awiqli - the world's first once-weekly basal insulin; going from daily to weekly injection reduces the need for injection pens, thereby reducing the plastic footprint of treatment by approximately two thirds compared to once daily treatment.®⢠In 2025, Awiqli was launched in two additional markets: Italy and Japan.⢠Target: Reduce our plastic footprint per patient by 30% by 2033.⢠Metric: 5.1.3 Plastic footprint per patient (kg/patient).Targets and performance In 2024, we set a voluntary global target to reduce our plastic footprint per patient by 30% by 2033 compared to base year 2024. The scope of the target includes plastic in devices and primary packaging for obesity and diabetes products. Internal and external experts were involved in setting the target. In 2024, we did not include primary packaging for needles for which we have made a restatement for our 2024 base year for both absolute- and relative plastic footprint, as well as our 2033 target value. The target addresses both resource inflows and outflows, including the minimisation of primary raw materials, converting to reusable devices and innovating treatment methods. Achieving this target requires treating patients with fewer devices and/or delivery solutions with lower plastic footprints, which addresses both resource inflows and outflows and relates to the waste prevention layer of the waste hierarchy. In 2025, we achieved a 5% reduction from 0.38 kg/patient in 2024 to 0.36 kg/patient mainly driven by an increase in once-weekly treatments combined with a reduction of once-daily treatments (see graph 5.1.3 in the margin). Resource outflows leaving Novo Nordisk include medicines, injection devices, packaging materials and waste. Key products aligned with circularity principles are our reusable devices. A conservative estimate of recyclable content in our products' packaging is 29%, reflecting the lowest share of recyclable content across they key geographies (Europe, US and Japan) according to our product lifecycle assessments (LCAs). Some products in certain geographies have a recyclable content in packaging of 29%, while in other geographies or for other products the recyclable content can be as high as 92%. 5.1.1 Resource outflows 2025 2024 20231Plastic footprint (absolute) (tonnes) 16,463 17,128 â2Plastic footprint per patient (kg/patient)0.36 0.38 âRecyclable content in products packaging 29% 28% â1. Plastic footprint (absolute) restated from 15,654 to 17,128 tonnes in 2024 due to the inclusion of primary packaging for needles. 2. Relative plastic footprint restated from 0.35 to 0.38 in 2024.With business growth, the total weight of technical and biological materials used in manufacturing of our medicines increased by 15%. As in 2024, about two-thirds were technical materials and one-third was biological components. In 2025, we took the first steps to source glucose from regenerative agriculture, enabling us for the first time to report a share of sustainably sourced biological materials of 11%.5.1.2 Resource inflows 1,000 tonnes 2025 2024 2023Overall total weight of technical and biological materials used 259 226 âPercentage of biological materials (and biofuels used for non-energy purposes) that are sustainably sourced 11% 0% âTo address our waste impact, we have a global target of zero landfill from production sites by 2030. In 2025, we refined the methodology to allow up to 0.05% of waste to landfill, e.g., due to local infrastructure or national regulation. In 2025, out of a total of 174 tonnes waste directed to landfill, 154 tonnes were generated in production, corresponding to 0.06% of our total production waste. This represents a 64% increase compared to production-related waste directed to landfill in 2024 (94 tonnes). This increase was entirely attributable to recent acquisitions. The acquired sites accounted for over 80% of all waste sent to landfill during 2025.At Novo Nordisk, the major waste streams include non-hazardous organic waste (e.g., yeast slurry), water waste (hazardous) and ethanol waste (hazardous). Total waste increased by 18% from 2024 to 2025, driven primarily by a rise in production waste. The increase in production waste was mainly caused by a temporary shift in the handling of yeast slurry, where it in 2025 was disposed of a higher water content, thereby resulting in a larger volume of production waste.In 2025, we managed to reduce our hazardous waste by 9% to 48,282 tonnes. The decline was largely due to lower ethanol and water waste volumes. The share of hazardous waste in total waste therefore declined.5.1.4 Resource outflows - Waste Tonnes2025 2024 2023Total waste generated 271,771 229,690 189,091 TotalNon-recycled waste 33,416 34,132 -Percentage of non-recycled waste 12% 15% -Total hazardous waste 48,282 52,982 Waste diverted from disposal 24,145 26,713 -⢠Preparation for Reuse 43 - -⢠Recycling 16,561 14,099 -Hazardous ⢠Other recovery operations 7,541 12,614 -Waste directed to disposal 24,137 26,269 -⢠Incineration 24,129 26,022 -⢠Landfill 8 0 -⢠Other disposal operations 0 247 -Total non-hazardous waste 223,489 176,708 Waste diverted from disposal 214,210 168,845 -⢠Preparation for Reuse 981 40 -⢠Recycling 197,810 149,853 -Non-hazardous⢠Other recovery operations 15,419 18,952 -Waste directed to disposal 9,279 7,863 -⢠Incineration 9,113 7,743 -⢠Landfill 166 120 638⢠Other disposal operations 0 - -ACCOUNTING POLICIES Overall total weight of technical and biological products and materials Total amount of materials used in our operations. Technical materials cannot be processed by the biological cycle, while biological materials can. Total weight includes all raw materials, associated process materials and semi-manufactured goods or parts sourced into production. Approximately 2% of the total cannot be categorised into biological or technical material but is still included in the total. No material was included in both categories to avoid double-counting. Sustainably sourced biological materials are biological materials grown in a way that preserves the eco-system without degrading it further but might fall short of being regeneratively produced. Biological materials sourced from regenerative agriculture or eco-labelled with e.g., FSC or PEFC are included. Recyclable content in packaging Novo Nordiskâs definition of recyclable content reflects practical recyclability in line with the Ellen McArthur Foundationâs definition and the EU Packaging and Packaging Waste Regulation. For recyclable content in product packaging, data on total packaging weights by geography have not been available and the metric shows the lower end of the range of recyclable content across markets and not the weighted average. Plastic footprintAbsolute plastic footprint is defined as the total amount of plastic placed on the market by Novo Nordisk in connection with obesity and diabetes products, including plastic from Novo Nordisk devices (pens and needles) and primary packaging (e.g., cartridges, vials, blister packs and tablet bottles). The metric does not capture additional plastic used in the process. Plastic footprint per patient refers to the absolute volume divided by patients reached.Total waste generated by Novo Nordisk Waste handled by a certified waste management company, measured by weight receipts or other data from the waste management company, including all waste fractions and disposal methods. Waste data for offices and affiliates outside Denmark are extrapolated based on headcount data available for their Danish counterparts. All waste subcategories are split between hazardous and non-hazardous waste according to the EUâs Waste Framework Directive. Construction waste is not included.Non-recycled waste refers to all waste (hazardous and non-hazardous) directed to disposal by incineration, both with and without energy recovery, by landfill at designated landfill sites and by other disposal operations. Other material topicsWorkers in the value chainNaturePollutionBusiness conductAmbition Safeguarding human rights, protecting labour and social rightsEnsuring safe, secure and healthy working conditions and preserving the environment and climate.Policy Responsible Sourcing StandardHuman Rights CommitmentModern Slavery Act StatementPerformance⢠19 Responsible Sourcing Audits performed in 2025 For more information on supplier engagement and our Compliance Hotline, see section 9.2 on page 766. Workers in the value chainIRO name Category Sustainability topic Value chain locationProtect labour rights and health ⢠Working ⢠Upstreamand safetyconditions⢠DownstreamPotential human rights violations⢠Other work-⢠Upstreamrelated rights⢠DownstreamMaterial impacts, risks and opportunitiesNovo Nordisk depends on a global value chain that spans more than 150 countries and includes over 54,000 suppliers delivering goods and services. Supplier representation is highest in Denmark, China and India. Value chain workers include contractors on expansion projects, manufacturing staff for sourced materials and logistics and warehouse partners. We have identified higher-risk areas among our direct suppliers related to device components, medical consumables, primary packaging, construction, warehousing and logistics in specific geographies. Despite our efforts to minimise negative impacts on value chain workers and their labour rights, we recognise the risks that exist where suppliers fail to meet our standards. Past impacts have been linked to health and safety incidents and suppliersâ deficiencies of supplier due diligence and management systems. 6.1 Working conditions and other work-related rightsPolicies and approach The Novo Nordisk Responsible Sourcing Standards¹ (RSS) set minimum requirements to our suppliers on responsible business conduct. The RSS covers protection of human, labour and social rights; prevention of bribery and corruption; environmental protection; and promotion of good governance, including protection of worker data and privacy. It is aligned with our Human 2Rights Commitment that prohibits forced labour, child labour and human trafficking, requiring suppliers to prevent such practices. With several global capacity expansion projects underway, we have implemented a new global minimum construction safety standard, that emphasises safety policies, providing protective equipment and training of workers.1.Aligned with UN Guiding Principles, OECD Guidelines, ILO Conventions and the Corporate Sustainability Due Diligence Directive (CSDDD). 2. Includes the International Bill of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and the Convention on the Rights of the Child.Annually, we provide training to our procurement organisation to reinforce their expertise and ensure the RSS is consistently incorporated into contracts. To ensure supplier adherence to the RSS, we conduct risk-based human rights and environmental due diligence to prevent, identify and address potential negative impacts. When impacts are identified, we develop and implement preventive measures in collaboration with our suppliers. In cases where Novo Nordisk causes or contributes to human rights impacts specifically, we commit to providing remedy. We conduct responsible sourcing audits for selected suppliers at risk-based frequencies. Audits assess implementation of our RSS through review of documentation, on-site visits and worker interviews. Besides these efforts, our procurement organisation and local RS Experts maintain regular engagement with suppliers and their representatives. Concerns, including human rights grievances, can be reported via our Compliance Hotline. For more information on the Hotline, see section 9.2 on p. 76. Suppliers are required to establish anonymous grievance mechanisms to ensure employees can raise issues without fear of retaliation.ActionsWe continuously strengthen our human rights and environmental due diligence processes using our due diligence tool. Full implementation of the tool is targeted by 2028. Throughout 2025, we continued our phased-in approach to ensure the RSS were included in all new and renegotiated contracts. We conducted 19 responsible sourcing audits (see accounting policy in section 9 'Business Conduct' p. 79). Where policy breaches were identified, we issued corrective action plans and monitored timely resolution and remediation. Besides these ongoing actions, we have also implemented the following key action in 2025:2025 actions Implementation of supplier due diligence tool⢠The tool enables automated risk screenings, covering areas such as human rights, environmental impacts and governance. The aim is to further strengthen responsible sourcing across our supply chain in compliance with evolving regulation. ⢠In 2025, we have initiated configuration of the tool with the future scope being active suppliers with spend recorded in the latest 12 months. ⢠We will continue configurations and implementation of the supplier due diligence tool in 2026. Other material topicsWorkers in the value chainNaturePollutionBusiness conductAmbitionWe aim to halt the loss of nature by 2033 and become nature positive by 2045 as guided by the Nature Roadmap. PolicyEnvironmental policyPerformance⢠Water withdrawal increased 15% since 2024Nature roadmapApproved in 2024, implementation will run from 2025â2045 and cover our entire value chain.Five broad ambitions⢠Avoid degradation of land⢠Reduce our relative impact on water at priority sites⢠Restore biodiversity at priority sites⢠Initiate restoration projects⢠Reduce and replace glucose7. Nature IRO name Category Sustainability topic Value chain locationReliance on water resources ⢠Water withdrawal⢠Upstreamand quality⢠Water discharge⢠Own operations⢠DownstreamPotential water scarcity risks ⢠Water withdrawal⢠Upstream⢠Own operationsReliance on natural resources ⢠Direct impact ⢠Upstreamand ecosystemsdrivers⢠Own operations⢠Impacts on the ⢠Downstreamcondition of ecosystems⢠Impacts and dependencies on ecosystem servicesDependency on vulnerable species ⢠Impact on the ⢠Upstreamfor safety testingstate of species⢠Own operationsMaterial impacts, risks and opportunitiesAs illustrated in 7.1.3 on the following page, our nature impacts occur through sourcing of raw materials of agricultural and forestry origin, where freshwater use, land-use change, deforestation and pollution (e.g., pesticides) can degrade ecosystems and lead to loss of natural habitats. We rely on natural resources, in particular agricultural inputs (such as glucose), forestry products (like paper), fossil-based materials (plastic) and other materials (such as glass) that can create dependencies that expose Novo Nordisk to short-, medium- and long-term risks that impact nature within areas such as water, biodiversity and land. The processes used to assess nature-related impacts are aligned with Science Based Targets Network (SBTN) and are based on primary activity data, lifecycle assessment databases and data on the state of nature in our value chain. Physical and transition risks were assessed through the World Wildlife Fund Biodiversity Risk Filter and through a qualitative scenario analysis, while dependencies on nature were assessed using the ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) tool. Water-related risks were assessed through production site screenings using the World Resources Instituteâs Aqueduct 4.0 tool and local water risk assessments. In 2025, we submitted our SBTN step 1 and 2 assessment (impacts and priorities) for validation by the Accountability Accelerator. Water is a critical resource for manufacturing Novo Nordiskâs products and for sourcing key commodities in our supply chain. For Novo Nordisk, risks related to water include potential water scarcity at production sites and in our supply chain and stricter water quality regulations in pharmaceutical production. Novo Nordisk also depends on certain species, notably horseshoe crabs, whose blood is used for endotoxin testing to ensure the safety of our products (see also section 9.5 'Bioethics and animal welfare', p. 78). To reduce our negative impact, we no longer use products from endangered horseshoe crab species (Tachypleus sp./TAL) and are working to phase out the use of products from vulnerable horseshoe crab species (Limulus sp./LAL).7.1 Water withdrawal and discharge, and biodiversityPolicies and approachGuided by our nature roadmap, our Environmental policy addresses key drivers of biodiversity loss such as water- and land use, over-exploitation, pollution and climate change to mitigate material impacts. We adhere to our nature roadmap aimed at contributing to a nature positive future in alignment with the Global Biodiversity Framework. We commit to protecting and restoring nature by managing impacts, dependencies and risks, collaborating with suppliers on sustainable land, forest and water management.The Environmental policy applies to all owned, leased, or managed operations, including those near biodiversity-sensitive areas, and covers water withdrawal for production sites and suppliers operating in areas of water stress. We aim to design water-efficient processes by reusing and recycling water, and ensuring production-related wastewater is treated according to regulations. While we do not yet have a formal deforestation policy, our nature roadmap sets an ambition for a deforestation- and conversion-free (DCF) value chain. We collaborate with our suppliers on raw material traceability. Transition and physical nature risks assessmentTo inform the development of our nature roadmap, we conducted a high-level resilience analysis of the exposure of our current business model to ecosystem-related risks. The analysis assumed two scenarios - one where we meet our nature ambitions and one where we do not with continuous nature degradation towards 2030 and 2050. The scope included upstream value chain of strategic raw materials in selected geographies, water withdrawal in our own operations and chemicals in water discharge. The results indicated that implementation of the roadmap could decrease our exposure to nature-related risks linked to raw material shortage and emerging deforestation regulation and highlighted the need for continued focus on water management. Novo Nordisk has therefore identified resource optimisation and reducing and replacing glucose as nature-related opportunities. Actions Through our nature roadmap, we have identified priority sites for action on biodiversity and water (see table 7.1.1). Priority sites (for water; and water and biodiversity) account for approximately 70% of the total water withdrawal. In 2025, we have mapped potential water savings at Kalundborg and Hillerød and will continue with the process for other priority sites setting savings targets for 2028. 7.1.1 Priority sitesWater Chartres (FR), Tianjin (CN)Water and biodiversity Kalundborg (DK), Hillerød (DK), Montes Claros (BR), Clayton (US)Biodiversity Durham (US), New Hampshire (US), Tietgenbyen (DK), Bagsværd (DK), Køge (DK)Priority sites for biodiversity action were identified based on impact and proximity to natural habitats or protected areas. With our ongoing actions we aim to reduce biodiversity impact and to enhance water conditions near production sites including replenishment, to ensure positive impacts by 2033. We initiated nature restoration projects near our priority sites, incorporating local knowledge, currently in China, with further projects planned in Brazil and USA.2025 actions Engaging priority suppliers water stewardship programme towards 2033 ⢠Screened and prioritised suppliers for engagement on water stewardship based on their water risks and maturity on the topic.Saving water and increasing wastewater treatment⢠Phasing out surface water withdrawal from Lake Tissø through industrial collaboration in 3Kalundborg (DK). Completion expected in 2026, with projected annual savings of 400,000 m⢠Expansion of on-site wastewater treatment operated by Novonesis, increasing the industrial wastewater and biomass treatment capacity. Completion expected in 2026.⢠Metric: 7.1.2 Water.Avoiding degradation of land in supply chain by sourcing glucose from regenerative agriculture. Programme running until 2033.⢠Supplier engagement to transition our glucose to regenerative sources to restore soils and reduce nature and carbon impacts. ⢠In 2025, more than 10% of the glucose we sourced was from regenerative sources.⢠Metric: 4.1.4Nature restoration near priority sites⢠In 2025, we entered into a partnership with Conservation International to restore 170 hectares of forest in the same water basin as our production site in Tianjin (China).⢠We made a landmark investment in a carbon removal initiative with Re.green to restore 500 hectares of Amazon rainforest in Brazil and capture over 87,000 tonnes of CO2 over the projectâs lifetime across 20 years.The majority of pressure on nature occurs through our sourcing of raw materials (see 7.1.3), particularly paper, cardboard and glucose. As part of our nature roadmap, to avoid the degradation of land, we are taking key actions, for example engaging with suppliers to source glucose from regenerative agriculture. We have also initiated the groundwork internally to ensure that our supply chain is in compliance with upcoming regulations such as the EU Deforestation Regulation 2026.We are continuously working on minimising and phasing out the use of biological products from vulnerable and endangered species, including LAL from the horseshoe crab, with most testing expected to end by 2027 (pending regulatory approval), and full discontinuation targeted for 2025â2035, both related to the internal Novo Nordisk processes. Performance In 2025, water withdrawals increased 15% primarily due to acquisitions of five production sites. 3 in savings, with additional 408,000 m3Our savings programme delivered 112,000 m estimated as water reused or recycled at our production facilities. We have not defined external water targets; however, as a part of our 2024 nature roadmap, we aim to reduce relative water impact at priority sites, with savings plans and targets in place by 2028. 7.1.2 Water 31,000 m2025 2024 2023Total water withdrawal 5,988 5,213 4,150Total water discharge 5,275 4,583 âTotal water recycled and reused 408 416 âACCOUNTING POLICIESTotal water withdrawal Includes all types of water such as drinking water, industrial water, steam water, water from remediation wells and rainwater. Data are based on meter readings and invoices (primary data). Data for offices and affiliates outside Denmark are extrapolated based on data available for their Danish counterparts (approximately 97% of the total is based on primary data). Total water discharge Includes discharge of process and sanitary water and discharge from storm water to outside Novo Nordiskâs boundaries, and water discharge used for irrigation. For sites where metered discharge data are not available, it has been assumed that water discharge equals water withdrawal. Total water recycled and reusedTotal quantity of water and water discharge (treated or untreated) that has been used more than once at the production sites before being discharged. The volume is estimated based on key indicators for specific water treatment equipment and technologies available at the sites. This includes steam condensate returned to steam generator, reverse osmosis water treatment and water discharge used for irrigation. The metric is estimated with a conservative approach.Other material topicsWorkers in the value chainNaturePollutionBusiness conductAmbitionOur ambition is to take ownership to reduce the use of toxic chemicals and minimise pharmaceuticals in the environment.Policy overview Environmental policyPerformance⢠Substances of very high concern declined overall since 2024Our chemical roadmapApproved in 2025, implementation will run from 2026â2033 and cover our entire value chain. Four focus areas to reduce SVHCs:⢠Design products⢠Design processes⢠Optimise and scale production⢠Develop data tools and enablers8. PollutionIRO name Category Sustainability topic Value chain locationUse of chemicals to produce ⢠Substances of very ⢠Upstreammedicines, devices and packaginghigh concern⢠Own operations⢠DownstreamMaterial impacts, risks and opportunitiesNovo Nordisk relies on biological processes and chemicals to produce medicines, devices and packaging. Our material impact is primarily linked to active pharmaceutical ingredient (API) production, which uses substances of very high concern (SVHCs) and other substances with 1same inherent properties, such as solvents. These can harm health and ecosystems if not handled safely. Almost all SVHCs and similar substances are subsequently collected as waste during production processes. Very small concentrations leave as emissions to air and water or in our products, primarily in devices or as preservatives for medicines.8.1 Substances of very high concernPolicies and approach Our Environmental policy commits us to responsible chemical management and to proactively eliminating SVHCs, similar substances and pollution. We strive to avoid the use of SVHCs and similar substances, when developing or designing new products and processes, whether own operations or outsourced, and to minimise or substitute their use for existing treatments. We reuse chemicals where feasible and ensure compliance with production site-specific environmental permits. We conduct annual environmental assessments at all production sites, covering waste, noise, water use/discharge, air, soil and groundwater. Breaches of regulatory terms are registered as a non-conformity, investigated and corrective actions implemented.Actions In 2025, we developed a new chemical roadmap to steer our efforts for the coming years based on two priorities: reducing SVHCs and similar substances and minimising the release of pharmaceuticals in the environment. We track the use of chemicals through various internal KPIs and environmental assessments. We work with innovation projects across in-house and outsourced production to reduce product impacts. During the product development process we screen for SVHCs and similar substances. Most medicines in our current portfolio and pipeline (e.g., CagriSema, Cagrilintide, IcoSema, Amycretin) are expected to be readily biodegradable and 2assessed to have no significant impact on the environment. 1. SVHCs are chemicals that have serious irreversible effects on human health or the environment, in accordance with REACH. Other substances with similar inherent properties, but currently not classified as SVHCs are referred to as âsimilar substancesâ in the remainder of this chapter2. The assessment has been performed according to the European Medicines Agencyâs Environmental Risk Assessment guideline.Besides these ongoing actions, we have also implemented the following key actions in 2025:2025 actionsReducing SVHCs and similar substances in production of medicines⢠Scope includes own production, contract manufacturers and suppliers.® and Wegovy®⢠In 2025, we optimised the manufacturing processes for Ozempic, oral GLP-1 products for obesity and diabetes and reduced the use of SVHCs in the process.⢠Metric: 8.1.1PerformanceIn 2025, procurement of SVHCs for our production decreased by 19%. We plan to further reduce their use through substitution or by purifying materials for reuse, which is part of our chemical roadmap. SVHCs leaving Novo Nordisk as emissions remained on par with 2024. In 2025, we identified a new SVHC in our devices and updated our 2024 data accordingly. This SVHC will be fully decommissioned by 2026, a culmination of one of our internal innovation projects, which is a development already seen in the 2025 performance of the metric. 8.1.1 Substances of very high concern Tonnes 2025 2024 2023Total amount of substances of very high concern that are procured 1,500 1,859 -Total amount of substances of very high concern leaving facilities as emissions, as products, or as part of products 0.8 1.5 -1⢠Substances leaving facilities as emissions 0.3 0.3 -2⢠Substances leaving facilities as products, or part of products 0.5 1.2 -1. 2024 value was overestimated and had to be restated from 1 to 0.3 tonnes. 2. 2024 value was restated from 0.003 to 1.2 tonnes due to a new SVHC identified in our devices.ACCOUNTING POLICIES Disclosures in Table 8.1.1 are manually calculated and carry a high degree of uncertainty. Substance weights are based on known concentrations; where this information is missing, we assume a concentration of 100%, which may lead to overestimation. The list of materials may not be fully complete. Hazard class categorisation is not applicable to substances of very high concern. Total amount of substances of very high concern (SVHCs) that are procured comprise the total weight of substances procured into production. Data sources include receipts of materials and purchase orders mapped against a chemical database.Total amount of SVHCs that leave facilities as emissions to air or water are based on available data for Denmark for our API production, Chemistry, Manufacturing and Control processes and Aseptic Manufacturing.Total amount of SVHCs that leave Novo Nordisk as products or part of products are defined as SVHCs identified either in excipients or devices. Data sources include production data (with final product quantities), bills of materials and purchase orders mapped against a chemical database.Other material topicsWorkers in the value chainNaturePollutionBusiness conductAmbition We define good ethics as conducting every interaction in a way that protects trust, prevents harm and promotes fairness, ensuring that our values are consistently embedded in daily practice and rooted in the practices of our founders.Policy OneCode policyLabour Code of ConductResponsible Sourcing StandardBioethics policyPerformance⢠Total supplier audits decreased by 6% since 2024⢠Animals purchased for research decreased 5% since 20249. Business conductIRO name Category Sustainability topic Value chain locationPromoting Novo Nordisk Way⢠Corporate culture⢠Own operationsTreating stakeholders in line with ⢠Protection of ⢠Upstreamethical standardswhistleblowers⢠Own operations⢠Corruption and ⢠Downstreambribery⢠Management of relationships with suppliers⢠Political influence and lobbyingPotential risks associated with breach ⢠Corruption and ⢠Upstreamof anti-corruption legislation Bribery⢠Own operations⢠DownstreamPromoting public health⢠Political ⢠Downstreamengagement and lobbyingPromoting bioethics⢠Bioethics⢠Own operationsReliance on animals ⢠Animal welfare⢠Upstreamin research⢠Own operationsMaterial impacts, risks and opportunitiesThe impacts and risks we have identified underpin our business model and strategy. We uphold ethics through integrity, anti-corruption, fair competition and protection of whistleblowers, safeguarding patient trust and market access. A strong corporate culture is promoted through the Novo Nordisk Way (NNWay), reinforcing ethical behaviour, accountability and compliance. Transparent advocacy and responsible political engagement and lobbying support healthcare resilience. Clear supplier expectations and responsible supplier management promote transparency and sustainability, reducing ethical, social and environmental risks. Stakeholder interests, including patients, healthcare professionals, suppliers and regulators, are integrated through structured engagement, supported by robust frameworks to prevent corruption, bribery and undue influence. High bioethical standards are central to protecting patients, research participants and society. Reliance on animals in research remains material to ensuring the safety, efficacy and quality of medicines, and we are committed to animal welfare and the continued pursuit of alternatives.Across these areas, we embed governance, training, due diligence and stakeholder consultation to reinforce resilience, preserve trust and align responsibility with long-term business growth. 9.1 Corporate culturePolicies and approachOur corporate culture is embedded in the Novo Nordisk Way and its 10 essentials (see right-side margin on the following page), which establishes expectations for how we act. Guided by the Board of Directors and Executive Management, our culture ensures that ethical principles are consistently acted on, shaping behaviours across the organisation and aligning business growth with integrity. Our OneCode policy translates these principles into practice, guiding all employees and third parties working on Novo Nordiskâs behalf in areas such as ethical decision making, workplace standards and our speak-up culture. We implement ongoing actions through our compliance framework, including annual Novo Nordisk Way facilitations, training, awareness programmes, supplier audits and whistleblowing procedures, which are embedded in our day-to-day governance and operations. We monitor adherence through reputational scores, engagement surveys and hotline reporting. We initiate follow-up action plans across all affiliates and sites on an ongoing basis with yearly cycles, with corrective measures implemented where gaps are identified and progress tracked.Performance A team of facilitators evaluates the adherence to the Novo Nordisk Way on selected units based on rotation every year. The units facilitated in 2025 represent 18,000 employees with interviews of ~3,000 employees and 800 close collaborators. One unit was found to be not operating in line with the NNWay and two units were assessed as borderline in their NNWay compliance. Immediate actions have been initiated, which if not taken would have lead to breaches of the Novo Nordisk Way. All other units were found in compliance, requiring no immediate actions. Key improvement opportunities reflected the increasingly volatile and competitive market environment in which Novo Nordisk operates in. 9.1.1 Facilitations of the Novo Nordisk WayNumber 2025 2024 2023Facilitations of the Novo Nordisk Way 63 51 429.2 Anti-corruption and anti-briberyPolicies and approachOur commitment to integrity is reflected in the OneCode policy, which prohibits any form of bribery and corruption in our operations and the value chain. Novo Nordisk integrates these into daily practice. Ethics and compliance training is mandatory for all employees globally. Annual e-learning and testing ensure awareness of anti-corruption and anti-bribery obligations, with completion rates monitored and followed up. Both shareholder-elected members and employee representatives ofthe Board of Directors receive annual training in our OneCode policy. Novo Nordisk has not formally defined functions at risk, but our policy applies to all employees and third parties acting on our behalf.Procedures are in place to prevent, detect and address allegations or incidents of corruption and bribery across all operations. Group Internal Audit conduct regular reviews and operate independently of management when investigating cases. Outcomes and trends from significant investigations are reported to the Audit Committee and Executive Management on a quarterly basis. Sanctions are guided globally by intent and frequency, applied consistently and in line with local laws and agreements.Employees and stakeholders can report ethical or legal concerns via our Compliance Hotline, whichoffers multiple formats and guarantees confidentiality, anonymity and protection from retaliation. Reports may address ethics breaches, financial misconduct, fraud, bribery, corruption, antitrust or data privacy violations, quality- or environmental issues, deviations from the Novo Nordisk Way, other serious offences such as espionage, sabotage, or information security breaches and animal use concerns (see section 9.5 'Bioethics and animal welfare, on page 78) and human rights considerations. Reports are investigated promptly, independently and objectively, and outcomes are monitored to ensure accountability and continuous improvement. The Compliance Hotline is regularly reviewed and independently assessed to ensure trust.We have zero tolerance for retaliation or discrimination against whistleblowers, good-faith reporters, supporting parties, or investigation participants as outlined in our anti-retaliation policy. Any retaliation against employees reporting misconduct will result in disciplinary action, including possible termination. The reporting channel 'Compliance Hotline' is described in detail both internally, on the intranet and externally, on the Novo Nordisk website. The mandatory annual compliance training courses also cover how to report suspected misconduct in a secure and confidential manner through the Compliance Hotline. Protections comply with the EU Whistleblowing Directive (2019/1937), with adherence to local laws during investigations outside Europe. Performance We continue to have almost full coverage of our global mandatory ethics and compliance training. Measures such as the annual Ethics Days support awareness, and we will continue to assess such initiatives in the future to strengthen performance. The amount of fines for violation of anti-corruption and anti-bribery laws was zero in 2025. In 2025, 261 substantiated cases were reported via the Compliance Hotline relating to accounting fraud and business ethics, which is an 8% increase compared to 2024. For substantiated cases, Novo Nordisk follows prescribed procedures to provide remedy.9.2.1 Anti-corruption and anti-bribery Number 2025 2024 2023Employees trained in ethics and compliance 99% 99% 99%Convictions for violation of anti-corruption and anti-bribery laws â â âSubstantiated cases reported within accounting issues, fraud and business ethics matters via the Compliance Hotline 261 242 2219.3 Management of relationships with suppliersPolicy and approachOur Global Procurement policy governs contracting from qualification and tendering to invoicing and spend management. It applies to indirect spend, while goods and services used in manufacturing are covered by dedicated internal standard operating procedures. We aim to promote transparency, fair treatment and sustainability through our engagement, while monitoring and mitigating ethical, social and environmental risks across the supply chain in line with the UN Guiding Principles on Business and Human Rights (see section 6 on 'Workers in the value chain', p. 71). We perform two types of supplier audits: quality audits and responsible sourcing audits. Quality audits qualify new suppliers and monitor performance through regular audits with risk-based frequencies, while audit requirements depend on usage categories and are governed through our manufacturing setup. Responsible sourcing audits cover factors such as country of operation and supplier spend. Procurement decisions are guided by our Responsible Sourcing Standards. We screen and evaluate suppliers and promote partnerships with preferred suppliers who demonstrate continuous improvement, innovation and reliable delivery. E-sourcing and e-auction tools ensure fast, fair and transparent negotiations.Performance The number of supplier audits have been reduced from 429 in 2024 to 403 in 2025, which is within the normal fluctuation associated with routine audits and requests for qualification audits. We continue to focus on conducting supplier audits as a key tool for identifying potential deviations from Novo Nordiskâs policies. No critical findings related to responsible sourcing or quality audits were issued during 2025. 9.3.1 Supplier auditsNumber 2025 20242023Total supplier audits 403 429382Our standard payment term is 60 days, for SMEs this is 30 days to ensure timely payments. In 2025, the overall average time to pay invoices increased by 5% mainly due to longer clearing time after processing and due to a general extension of payment terms. Percentage of payments aligned with standard payment terms defined in our Payment Guideline has increased by 2% points overall since 2024. We remain firmly committed to preventing late payments, particularly for small enterprises, and had no outstanding legal proceedings related to late payments in 2025.9.3.2 Payment practicesDays 2025 2024 2023Average number of days to pay invoice 44 42 â⢠Small suppliers 26 24 â⢠Large suppliers 50 49 âPercentage of payments aligned with standard payment terms 85% 83% â⢠Small suppliers 82% 77% â⢠Large suppliers 85% 84% âOutstanding legal proceedings for late payments (Number) 0 0 â9.4 Political influence and lobbying activitiesPolicies and approachOur OneCode policy sets out clear commitments for ethical political engagement. We stand by the objectives of having patientsâ interests as our priority, acting with professionalism and integrity. We apply a zero-tolerance policy on offering any undue influence, gifts, or favours to public officials or decision-makers, including zero-tolerance with regards to in-kind political contributions. No member of our Board of Directors has held a comparable position in public administration in the two years preceding their appointment. Our lobbying activities primarily focus on public health policy and access to medicines and are intended to support the material positive impact identified in the DMA related to promoting public health.We participate in national and international industry associations to advance broad policy issues. Memberships are regularly assessed for alignment with Novo Nordiskâs objectives and advocacy priorities. We support industry-wide initiatives and regulations that promote: evidence-based chronic disease prevention, patient care and healthcare resilience through innovation, sustainable pharma practices and optimal conditions for discovery. We ensure transparent disclosure of advocacy priorities and provide global staff guidance. Lobbying in the EU and US is reported annually, reviewed, corrected when needed and tracked through yearly activity and expenditure reports. We are registered in the EU Transparency Register (REG no. 29570313329-11).ActionsThrough our engagement with various stakeholders, such as industry and trade associations, we have taken actions for the implementation of our objectives. Besides these ongoing actions, we have also implemented the following key actions in 2025:2025 actions Advocacy via EFPIA⢠Advocacy via the EFPIA Obesity Policy Platform to advance care for people living with obesity, recognise it as a relapsing chronic disease and highlight its economic burden.⢠Ongoing collaboration with the EFPIA Health Systems Working Group to tackle key challenges to health system resilience.Advocacy via European Diabetes Forum⢠Advocacy through the European Diabetes Forum for policy change that enables healthcare systems to better manage diabetes care.Approach to suppliers and sustainability We engage suppliers through a risk-based approach, guided by global standards (UNGP, OECD, CSDDD), with audits, corrective actions and continuous improvement requirements. Our supplier selection and management embed sustainability criteria, ensuring labour rights including health and safety, human rights, and environmental stewardship are central to every partnership.We hold suppliers accountable through due diligence, requiring documentation, risk assessments and enforcing consequences for non-compliance.RSS applies globally but we emphasise proportionate support for SMEs, enabling inclusion of smaller and local suppliers in our supply chain.Performance In 2025, a new metric on financial political contributions was introduced, namely 'Amount disclosed in the EU Transparency Register'. The metric replaced the previously reported metric 'Trade association membership fees' to ensure greater consistency with peers and use already publicly available data. The financial contributions are paid to target EU pharmaceutical-related policy, as well as broader health, environmental and business-related policy. In accordance with our zero-tolerance policy, we did not make any in-kind political contributions in 2025. 9.4.1 Financial and in-kind political contributions mademDKK 2025 20242023Amount disclosed in the EU Transparency Register 8.2â9 â âIn-kind political contributions made ââ â9.5 Bioethics and animal welfarePolicies and approachOur Bioethics policy sets operational guidelines for R&D to uphold high global ethical standards in research involving people, animals, human materials and gene technology. These extend to partners, Contract Research Organizations (CROs) and suppliers with performance monitored through oversight processes. Our commitments are detailed in publicly available position statements on clinical trials, human biosamples, animal ethics, gene therapy and technology.We uphold high standards of animal welfare, fully aligning with EU Directive 2010/63/EU and the Marseille Declaration, and collaborating with regulators, NGOs, researchers and welfare 1organisations to advance ethics and transparency. Our Bioethics policy embeds these strict welfare requirements for all animals purchased for research, whether conducted in-house or by contractors. It follows the 3R principles (Replace, Reduce, Refine) and sets clear standards for animal housing, care, transport and health monitoring, ensuring every precaution has been considered. As mentioned under section 7 'Nature', we continuously work on minimising the use of products from vulnerable and endangered species such as the horseshoe crab. Use of non-human primates is approached with care and consideration, and is limited to cases only where necessary, i.e. where homology to the human genome is essential when testing potential new therapies. Oversight mechanisms include veterinarians, animal unit managers and our Ethical Review Council, which reviews all studies involving living and sentient animals performed at, or on behalf of, Novo Nordisk. 1. These include the Danish Animal Welfare Society, the UKâs Royal Society for the Prevention of Cruelty to Animals, the Danish Association of the Pharmaceutical Industry and the Universities Federation for Animal Welfare.Performance The number of animals purchased for research in 2025 has decreased by 5% compared to 2024, due to our continuous efforts to reduce the number of animals used in research. In 2025, 96% of the animals were rodents. The increased use of dogs and non-human primates in 2025 are driven by an increased number of late-stage research projects in the portfolio (pre-clinical development), resulting in a higher demand for regulatory-required studies. It also reflects the nature and maturity of the research projects, where species qualification determines the number needed for testing in dogs and non-human primates.9.5.1 Animals purchased for researchNumber 2025 2024 2023Mice, rats and other rodents 44,917 47,478 54,410Pigs 521 615 608Rabbits 214 689 289Dogs 529 126 356Non-human primates 475 366 807Fish 202 0 36Other vertebrates 11 10 2Total animals purchased 46,869 49,284 56,508ACCOUNTING POLICIES Facilitations of the Novo Nordisk WayA facilitation is an internal process for assessing adherence to the Novo Nordisk Way. The number of facilitations is measured as the number of facilitations completed. The assessments are based on a review of documentation and feedback from stakeholders, followed by an on-site visit during which randomly selected employees and management are interviewed. Identified gaps and improvement opportunities related to the Novo Nordisk Way are presented to, and discussed with, Executive Management. The facilitators and Executive Management agree on an action plan to address any gaps and improvement opportunities.Employees trained in ethics and compliance The mandatory ethics and compliance training for employees working at Novo Nordisk comprises globally applicable e-learning. The percentage of employees trained is calculated as the number of employees that have completed the training divided by the total number of employees (invited to the training) at year-end. We exclude employees on long-term leave, externals as well as student assistantsNumber and amount of convictions for violation of anti-corruption and anti-bribery lawsAnti-corruption and anti-bribery instances where any reported undertaking including parent or affiliated entities has been found in violation by a court of law. Disclosures include incidents involving actors in ourvalue chain only where Novo Nordisk or its employees are directly involved.Substantiated cases of accounting, fraud and business ethics reported via the Compliance HotlineNumber of cases reported to the Compliance Hotline, where reported allegations of suspected misconduct have been substantiated or partially substantiated (partially substantiated is defined as an allegation which encompasses several aspects, but only a subset of them can be confirmed). When a case has been substantiated or partially substantiated, corrective actions are initiated. Average number of days to pay invoiceAverage number of days it takes Novo Nordisk to settle an invoice from the invoice date (when contractual or statutory term of payment starts to be calculated) until the invoice has been cleared. The three fill-finish Catalent sites acquired in 2024 are not included in this metric for 2025. SME invoices are measured against a 30-day standard, i.e. the proportion of SME invoices paid within 30 days of issue. For non-SME invoices, performance is measured against the actual due date stated on the invoice, in linewith the contractually agreed payment terms (most commonly 60 days, but other terms may apply).Percentage of payments aligned with standard payment termsIncludes all transactions where the invoice cycle time is equal to or less than the specified payment terms, divided by the total number of transactions. Small suppliers (with less than DKK 1 million in spend over the last twelve months) are measured based on 30-day payment terms, other suppliers are assessed using payment terms from the invoice document recorded in our internal systems. The three fill-finish Catalent sites acquired in 2024 are not included in this metric for 2025. Number of outstanding legal proceedings for late paymentsNumber of all outstanding legal proceedings (litigation or arbitration) for late payment.Supplier auditsTotal number of supplier audits, concluded by Novo Nordiskâs Corporate Quality and Inspections function, consisting of the number of responsible sourcing audits and quality audits conducted at suppliers, selected using various risk parameters. Audits for responsible sourcing are conducted according to Novo Nordiskâs Responsible Sourcing Standard to ensure compliance. In addition, suppliers of goods and services used in the manufacture of Novo Nordisk pharmaceuticals are subject to extensive quality audits in accordance with different quality standards, including third-party audits. The three fill-finish Catalent sites acquired in 2024 are not included in this metric for 2025. Amount disclosed in the EU Transparency RegisterNovo Nordisk discloses the annual costs in DKK related to activities (lobbying and advocacy activities) covered by the EU Transparency Register for the reporting year.In-kind political contributionsIn-kind contributions can include advertising, use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for office.Animals purchased for researchNumber of animals purchased for all research undertaken by Novo Nordisk, either in-house or by external contractors. It is based on internal registration of purchased animals and yearly reports from external contractors.10. EU TaxonomyOn 04 July 2025, the European Commission introduced simplification measures for the EU Taxonomy under a new Delegated Act, effective 1 January 2026 and applicable to the 2025 financial year. We have chosen to adopt the new rules already for financial year 2025. Taxonomy-eligibility- and alignmentTo identify potentially eligible economic activities, we have screened all the activities listed in our financial statement and cross-referenced them with the EU Taxonomyâs list of eligible activities. In performing the screening, we have only considered activities that were contributing to at least 10% cumulatively of the relevant KPI. For non-material economic activities, please refer to the 'Additional Sustainability statement information' p. 135. The eligibility screening resulted in the following activities being identified as relevant to Novo Nordisk:⢠7.1 Construction of new buildings (environmental objective 'Climate change mitigation'): Relevant for CapEx (eligibility and alignment)⢠7.2 Renovation of existing buildings (environmental objective 'Climate change mitigation'): Relevant for CapEx (eligibility)⢠1.2 Manufacture of medicinal products (environmental objective 'Pollution prevention and control'): Relevant for the Turnover and CapEx KPIs (eligibility)1 Novo Nordisk adjusted EU Taxonomy overviewTurnover CapEx2025 2025Environmental objective Economic activity (mDKK) (%) (mDKK) (%)Total Turnover and CapEx 309,064 100 94,249 100Not assessed activities considered non-material 0 0 2,491 3Taxonomy-non-eligible activities 0 0 26,282 28Climate change mitigation 7.1 Construction of new buildings 17,298 187.2 Renovation of existing buildings 2,472 3Pollution prevention and control 1.2 Manufacture of medicinal products 309,064 100 39,871 42Eligible not aligned 309,064 100 59,641 63Eligible and aligned 7.1 Construction of new buildings0 0 5,835 61. See mandatory reporting templates Tables 5a, 5b and 5c in 'Additional Sustainability statement information' on p. 135 and 136PerformanceNovo Nordisk has assessed the technical screening criteria for eligible economic activities deemed material. The summary for 2025 can be seen below:⢠7.1: 6% of our CapEx investments in 2025 related to new building constructions are Taxonomy-aligned. In addition to the two major ongoing construction projects that we began aligning to Taxonomy requirements last year, three more construction projects meet the criteria for Taxonomy-alignment. While certain criteria have yet to be fulfilled due to the relevant construction phases not being reached, we are confident in their fulfilment based on pre-calculations from the design phases and the implementation of appropriate controls throughout the entire construction process. With regard to our assumptions from the previous year, there are no changes. ⢠7.2: We were not able to claim alignment for this activity in 2025, and we do not currently have any plans to pursue alignment in the future.⢠1.2: In continuation of our assessment of alignment criteria focused on our Danish ® and Wegovy®manufacturing sites for Ozempic, we have explored opportunities to close gaps where feasible. We still face challenges in securing evidence for, or addressing the practical aspects of certain criteria. In light of the review of the existing EU Taxonomy screening criteria related to the EU Omnibus package, we have decided to await the revised and updated requirements before proceeding further.EU TaxonomyThe EU Taxonomy is a classification system with a shared definition of economic activities identified as environmentally sustainable, in accordance with established technical criteria.Contextual information about the KPIs⢠We consider all Novo Nordiskâs turnover Taxonomy-eligible under economic activity 1.2 'Manufacture of medicinal products'. ⢠Taxonomy-eligible CapEx includes only CapEx directly associated with the manufacturing process or related to construction or renovation of buildings; intangible assets are included (excluding goodwill).⢠Eligible CapEx mainly relates to equipment for manufacture of medicinal products and additions to property, plant and equipment, as per note 3.3 'Property, plant and equipment' on p. 96 in the Consolidated financial statementFor a description of our Taxonomy disclosure process, incl. substantial contribution and 'do no significant harm' (DNSH), accounting policies and the mandatory reporting templates, please refer to the 'Additional Sustainability statement information', p. 135.</mrv:SustainabilityReport>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx-1" id="f1__s10__8__32" xml:lang="en">10. EU TaxonomyOn 04 July 2025, the European Commission introduced simplification measures for the EU Taxonomy under a new Delegated Act, effective 1 January 2026 and applicable to the 2025 financial year. We have chosen to adopt the new rules already for financial year 2025. Taxonomy-eligibility- and alignmentTo identify potentially eligible economic activities, we have screened all the activities listed in our financial statement and cross-referenced them with the EU Taxonomyâs list of eligible activities. In performing the screening, we have only considered activities that were contributing to at least 10% cumulatively of the relevant KPI. For non-material economic activities, please refer to the 'Additional Sustainability statement information' p. 135. The eligibility screening resulted in the following activities being identified as relevant to Novo Nordisk:⢠7.1 Construction of new buildings (environmental objective 'Climate change mitigation'): Relevant for CapEx (eligibility and alignment)⢠7.2 Renovation of existing buildings (environmental objective 'Climate change mitigation'): Relevant for CapEx (eligibility)⢠1.2 Manufacture of medicinal products (environmental objective 'Pollution prevention and control'): Relevant for the Turnover and CapEx KPIs (eligibility)1 Novo Nordisk adjusted EU Taxonomy overviewTurnover CapEx2025 2025Environmental objective Economic activity (mDKK) (%) (mDKK) (%)Total Turnover and CapEx 309,064 100 94,249 100Not assessed activities considered non-material 0 0 2,491 3Taxonomy-non-eligible activities 0 0 26,282 28Climate change mitigation 7.1 Construction of new buildings 17,298 187.2 Renovation of existing buildings 2,472 3Pollution prevention and control 1.2 Manufacture of medicinal products 309,064 100 39,871 42Eligible not aligned 309,064 100 59,641 63Eligible and aligned 7.1 Construction of new buildings0 0 5,835 61. See mandatory reporting templates Tables 5a, 5b and 5c in 'Additional Sustainability statement information' on p. 135 and 136PerformanceNovo Nordisk has assessed the technical screening criteria for eligible economic activities deemed material. The summary for 2025 can be seen below:⢠7.1: 6% of our CapEx investments in 2025 related to new building constructions are Taxonomy-aligned. In addition to the two major ongoing construction projects that we began aligning to Taxonomy requirements last year, three more construction projects meet the criteria for Taxonomy-alignment. While certain criteria have yet to be fulfilled due to the relevant construction phases not being reached, we are confident in their fulfilment based on pre-calculations from the design phases and the implementation of appropriate controls throughout the entire construction process. With regard to our assumptions from the previous year, there are no changes. ⢠7.2: We were not able to claim alignment for this activity in 2025, and we do not currently have any plans to pursue alignment in the future.⢠1.2: In continuation of our assessment of alignment criteria focused on our Danish ® and Wegovy®manufacturing sites for Ozempic, we have explored opportunities to close gaps where feasible. We still face challenges in securing evidence for, or addressing the practical aspects of certain criteria. In light of the review of the existing EU Taxonomy screening criteria related to the EU Omnibus package, we have decided to await the revised and updated requirements before proceeding further.EU TaxonomyThe EU Taxonomy is a classification system with a shared definition of economic activities identified as environmentally sustainable, in accordance with established technical criteria.Contextual information about the KPIs⢠We consider all Novo Nordiskâs turnover Taxonomy-eligible under economic activity 1.2 'Manufacture of medicinal products'. ⢠Taxonomy-eligible CapEx includes only CapEx directly associated with the manufacturing process or related to construction or renovation of buildings; intangible assets are included (excluding goodwill).⢠Eligible CapEx mainly relates to equipment for manufacture of medicinal products and additions to property, plant and equipment, as per note 3.3 'Property, plant and equipment' on p. 96 in the Consolidated financial statementFor a description of our Taxonomy disclosure process, incl. substantial contribution and 'do no significant harm' (DNSH), accounting policies and the mandatory reporting templates, please refer to the 'Additional Sustainability statement information', p. 135.</mrv:DescriptionofTheTaxonomyRegulation>
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<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx-1" id="f1__s10__8__190" xml:lang="en">The Board of Directors and Executive Management have today considered and approved the Annual Report of Novo Nordisk A/S for the financial year 1 January 2025 â 31 December 2025. The Consolidated financial statements are prepared in accordance with IFRS Accounting Standards as adopted by the EU and disclosure requirements for listed companies in Denmark. The parent financial statements are presented in accordance with the Danish Financial Statements Act. Furthermore, the Annual Report is prepared in accordance with disclosure requirements for listed companies.In our opinion, the Consolidated financial statements and the parent financial statements give a true and fair view of the Groupâs and the Parent's financial position at 31 December 2025 as well as of the results of their operations and the Group's cash flows for the financial year 1 January 2025 â 31 December 2025. In our opinion, the Management report is prepared in accordance with relevant laws and regulations and contains a fair review of the development of the Group's and the In our opinion, the Management report is prepared in accordance with relevant laws and regulations and contains a fair review of the development of the Group's and the Parentâs business and financial matters, the results for the year and of the Parentâs financial position and the financial position as a whole of the entities included in the Consolidated financial statements, together with a description of the principal risks and uncertainties that the Group and the Parent face.The Sustainability statement is prepared in accordance with the European Sustainability Reporting Standards (ESRS) as required by the Danish Financial Statements Act, as well as article 8 in the EU Taxonomy regulation.Furthermore, in our opinion, the Annual Report of Novo Nordisk A/S for the financial year 1 January 2025 â 31 December 2025, with the file name NOVO-2025-12-31-1-en, is prepared, in all material respects, in accordance with the ESEF Regulation.We recommend the Annual Report for adoption at the Annual General Meeting.</sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx-1" id="f1__s10__8__191" xml:lang="en">Bagsværd</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx-1" id="f1__s10__8__192">2026-02-04</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-37" id="f1__s10__8__193" xml:lang="en">Maziar Mike Doustdar</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-37" id="f1__s10__8__194" xml:lang="en">President and Chief Executive Officer (CEO)</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-38" id="f1__s10__8__195" xml:lang="en">Karsten Munk Knudsen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-38" id="f1__s10__8__196" xml:lang="en">Chief Financial Officer (CFO)</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-39" id="f1__s10__8__197" xml:lang="en">Lars Rebien Sørensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-39" id="f1__s10__8__198" xml:lang="en">Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-40" id="f1__s10__8__199" xml:lang="en">Cees de Jong</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-40" id="f1__s10__8__200" xml:lang="en">Vice Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-41" id="f1__s10__8__201" xml:lang="en">Elisabeth Dahl Christensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-42" id="f1__s10__8__202" xml:lang="en">Stephan Engels</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-43" id="f1__s10__8__203" xml:lang="en">Liselotte Hyveled</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-44" id="f1__s10__8__204" xml:lang="en">Mette Bøjer Jensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-45" id="f1__s10__8__205" xml:lang="en">Britt Meelby Jensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-46" id="f1__s10__8__206" xml:lang="en">Kasim Kutay</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-47" id="f1__s10__8__207" xml:lang="en">Tanja Villumsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="f1__s10__8__212" xml:lang="en">To the shareholders of Novo Nordisk A/S</arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx-1" id="f1__s10__8__213" xml:lang="en">OpinionWe have audited the consolidated financial statements and the parent financial statements of Novo Nordisk A/S for the financial year 1 January 2025 â 31 December 2025, which comprise the income statement, balance sheet, equity statement and notes, including a summary of material accounting policy information, for the Group as well as the Parent, and the statement of comprehensive income and the cash flow statement of the Group (collectively referred to as the âFinancial Statementsâ). The Consolidated financial statements are prepared in accordance with IFRS Accounting Standards as endorsed by the EU and additional disclosure requirements for listed entities in Denmark, and the parent financial statements are prepared in accordance with the Danish Financial Statements Act. In our opinion, the consolidated financial statements give a true and fair view of the Groupâs financial position at 31 December 2025, and of the results of its operations and cash flows for the financial year 1 January 2025 â 31 December 2025 in accordance with IFRS Accounting Standards as endorsed by the EU and additional disclosure requirements for listed entities in Denmark. Furthermore, in our opinion, the parent financial statements give a true and fair view of the Parentâs financial position at 31 December 2025, and of the results of its operations for the financial year 1 January 2025 â 31 December 2025 in accordance with the Danish Financial Statements Act. Our opinion is consistent with our long-form auditor's report issued to the Audit Committee and the Board of Directors.</arr:OpinionOnAuditedFinancialStatements>
<arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx-1" id="f1__s10__8__214" xml:lang="en">Basis for opinionWe conducted our audit in accordance with International Standards on Auditing (ISAs) and the additional requirements applicable in Denmark. Our responsibilities under those standards and requirements are further described in the âAuditorâs responsibilities for the audit of the Financial Statementsâ section of this auditorâs report. We are independent of the Group in accordance with the International Ethics Standards Board for Accountantsâ International Code of Ethics for Professional Accountants (IESBA Code), as applicable to audits of financial statements of public interest entities, and the additional ethical requirements applicable in Denmark to audits of financial statements of public interest entities. We have also fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.To the best of our knowledge and belief, we have not provided any prohibited non-audit services as referred to in Article 5(1) of Regulation (EU) No 537/2014.We were appointed auditors of Novo Nordisk A/S for the first time on 25 March 2021, for the financial year 2021. We have been reappointed annually by decision of the general meeting for a total continuous engagement period of five years up to and including the financial year 2025.</arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:KeyAuditMattersAudit contextRef="ctx-1" id="f1__s10__8__215" xml:lang="en">Key audit mattersKey audit matters are those matters that, in our professional judgement, were of most significance in our audit of the consolidated financial statements and the parent financial statements for the financial year 1 January 2025 â 31 December 2025. These matters were addressed in the context of our audit of the consolidated financial statements and the parent 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 US sales rebatesRefer to notes 2.1 and 3.6 in the consolidated financial statements.In the United States (US), sales rebates are paid in connection with public healthcare insurance programs, namely Medicare and Medicaid, as well as rebates to pharmacy benefit managers and managed healthcare plans. In January 2021, the Company changed its policy in the US related to the 340B Drug Pricing Program, whereby Novo Nordisk no longer provides 340B statutory discounts to certain pharmacies that contract with covered entities participating in the 340B Drug Pricing Program. Novo Nordisk has only recognised revenue related to the 340B Drug Pricing Program to the extent that it is highly probable that its inclusion will not result in a significant revenue reversal in the future. When sales are recognised, Novo Nordisk also records provisions for the expected value of the sales deductions (variable consideration) at the time the related sales are recorded.We identified the US sales rebates, including provisions related to the 340B Drug Pricing Program, as a key audit matter due to the significant measurement uncertainty involved in developing these provisions, as the provisions are based on legal interpretations of applicable laws and regulations, historical claims experience, payer channel mix, current contract prices, unbilled claims, claims submission time lags and inventory levels in the distribution channel. In addition, significant judgment was required to determine whether, at 31 December 2025, it was deemed highly probable that a significant reversal of revenue would not occur. This led to a high degree of auditor judgment and an increased extent of eï¬ort in applying procedures relating to these provisions.How the matter was addressed in our auditWe evaluated the appropriateness of the Companyâs methodology used to develop their sales rebates provisions, including provisions related to the 340B Drug Pricing Program, by involving audit professionals with industry and quantitative analytics experience to assist us in performing our auditing procedures.We tested the eï¬ectiveness of controls relating to sales rebates, including controls over the assumptions and data used to estimate these rebates.We tested rebate claims processed by the Company, including evaluating those claims for consistency with the conditions and terms of the Companyâs rebate arrangements.We tested the overall reasonableness of the accruals recorded at period end by developing an expectation for comparison to actual recorded balances.We evaluated the Companyâs ability to estimate sales rebates accurately by considering the historical accuracy of the Companyâs estimates in prior year.We evaluated the accounting for subsequent events related to the 340B Drug Pricing Program, including consulting with our accounting specialists related to the Companyâs conclusions.</arr:KeyAuditMattersAudit>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="f1__s10__8__216" xml:lang="en">Statement on the Management reportManagement is responsible for the Management report.Our opinion on the consolidated financial statements and the parent financial statements does not cover the Management report, and we do not express any form of assurance conclusion thereon.In connection with our audit of the consolidated financial statements and the parent financial statements, our responsibility is to read the Management report and, in doing so, consider whether the Management report is materially inconsistent with the consolidated financial statements and the parent financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated.Moreover, it is our responsibility to consider whether the Management report provides the information required by the Danish Financial Statements Act. This does not include the requirements in section 99a related to the Sustainability statement covered by the separate auditorâs limited assurance report hereon.Based on the work we have performed, we conclude that the Management report is in accordance with the consolidated financial statements and the parent financial statements and has been prepared in accordance with the requirements of the Danish Financial Statements Act except for the requirements in section 99a related to the Sustainability statement, cf. above. We did not identify any material misstatement in the Management report.</arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx-1" id="f1__s10__8__217" xml:lang="en">Managementâs responsibilities for the Financial StatementsManagement is responsible for the preparation of consolidated financial statements that give a true and fair view in accordance with IFRS Accounting Standards as endorsed by the EU and additional disclosure requirements for listed entities in Denmark as well as the preparation of parent 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 consolidated financial statements and parent financial statements that are free from material misstatement, whether due to fraud or error.In preparing the consolidated financial statements and the parent financial statements, Management is responsible for assessing the Groupâs and the Parentâs ability to continue as a going concern, for disclosing, as applicable, matters related to going concern, and for using the going concern basis of accounting in preparing the consolidated financial statements and the parent financial statements unless Management either intends to liquidate the Group or the Entity or to cease operations, or has no realistic alternative but to do so.</arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx-1" id="f1__s10__8__218" xml:lang="en">Auditorâs responsibilities for the audit of the Financial StatementsOur objectives are to obtain reasonable assurance about whether the consolidated financial statements and the parent financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditorâs report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conductedin accordance with ISAs and the additional requirements applicable in Denmark will always detecta material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these consolidated financial statements and these parent financial statements.As part of an audit conducted 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 consolidated financial statements and the parent financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.⢠Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Groupâs and the Parentâs internal control.⢠Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by Management.⢠Conclude on the appropriateness of Managementâs use of the going concern basis of accounting in preparing the consolidated financial statements and the parent financial statements, and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group's and the Parentâs ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditorâs report to the related disclosures in the consolidated financial statements and the parent 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 and the Entity to cease to continue as a going concern.⢠Evaluate the overall presentation, structure and content of the Financial Statements, including the disclosures in the notes, and whether the Financial Statements represent the underlying transactions and events in a manner that gives a true and fair view.⢠Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial information of the entities or business units within the group as a basis for forming an opinion on the Financial Statements. We are responsible for the direction, supervision and review of the audit work performed for purposes of the group audit. We remain solely responsible for our audit opinion.We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and, where applicable, safeguards put in place and measures taken to eliminate threats.From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Financial Statements of the current period and are therefore the key audit matters. We describe these matters in our auditorâs report unless law or regulation precludes public disclosure about the matter.</arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx-1" id="f1__s10__8__219" xml:lang="en">Report on compliance with the ESEF RegulationAs part of our audit of the Financial Statements of Novo Nordisk A/S, we performed procedures to express an opinion on whether the annual report for the financial year 1 January 2025 â 31 December 2025, with the file name NOVO-2025-12-31-1-en, is prepared, in all material respects, in compliance with the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation), which includes requirements related to the preparation of the annual report in XHTML format and iXBRL tagging of the consolidated financial statements including notes.Management is responsible for preparing an annual report that complies with the ESEF Regulation. This responsibility includes:⢠The preparing of the annual report in XHTML 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 financial information required to be tagged using judgement where necessary;⢠Ensuring consistency between iXBRL tagged data and the consolidated financial statements presented in human readable format; and⢠For such internal control as Management determines necessary 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 compliance with the ESEF Regulation based on the evidence we have obtained, and to issue a report that includes our opinion. The nature, timing and extent of procedures selected depend on the auditorâs judgement, including the assessment of the risks of material departures from the requirements set out in the ESEF Regulation, whether due to fraud or error. The procedures include:⢠Testing whether the annual report is prepared in XHTML format;⢠Obtaining an understanding of the Companyâs iXBRL tagging process and of internal control over the tagging process;⢠Evaluating the completeness of the iXBRL tagging of the consolidated financial 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 consolidated financial statements.In our opinion, the annual report of Novo Nordisk A/S for the financial year 1 January 2025 â 31 December 2025, with the file name NOVO-2025-12-31-1-en is prepared, in all material respects, in compliance with the ESEF Regulation.</arr:AuditorsReportOnXbrlTagging>
<arr:SignatureOfAuditorsPlace contextRef="ctx-1" id="f1__s10__8__220" xml:lang="en">Copenhagen</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx-1" id="f1__s10__8__221">2026-02-04</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx-49" id="f1__s10__8__224" xml:lang="en">DeloitteStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
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<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-48" id="f1__s10__8__223">33963556</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-49" id="f1__s10__8__225">33963556</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:NameAndSurnameOfAuditor contextRef="ctx-48" id="f1__s10__8__226" xml:lang="en">Anders Vad Dons</cmn:NameAndSurnameOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx-49" id="f1__s10__8__229" xml:lang="en">Sumit Sudan</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx-48" id="f1__s10__8__227" xml:lang="en">State-Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx-49" id="f1__s10__8__230" xml:lang="en">State-Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx-48" id="f1__s10__8__228">mne25299</cmn:IdentificationNumberOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx-49" id="f1__s10__8__231">mne33716</cmn:IdentificationNumberOfAuditor>
<arr:AuditorsReportOnSubstainabilityReport contextRef="ctx-1" id="f1__s10__8__233" xml:lang="en">Independent auditorâs limited assurance report on Sustainability statementTo the stakeholders of Novo Nordisk A/SLimited assurance conclusionWe have conducted a limited assurance engagement on the Sustainability statement of Novo Nordisk A/S (the âGroupâ) included in the Management Report (the âSustainability statementâ),for the financial year 1 January â 31 December 2025.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 section 99a, 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 1.4 Double materiality assessment; and⢠compliance of the disclosures in 10. EU Taxonomy within the Other material topics information and EU Taxonomy â Contextual information, accounting policies and templates within the section Additional Sustainability statement information with Article 8 of EU Regulation 2020/852 (the âTaxonomy Regulationâ).Basis for conclusionWe conducted our limited assurance engagement in accordance with ISAE 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information, and additional requirements applicable in Denmark.The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.We believe that the evidence we have obtained is sufficient and appropriate to provide a basisfor our conclusion. Our responsibilities under this standard are further described in the âAuditorâs responsibilities for the assurance engagementâ section of our report.Our independence and quality managementWe are independent of the Group in accordance with the International 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 accordance with these requirements and the IESBA Code.Deloitte Statsautoriseret Revisionspartnerselskab applies International Standard on Quality Management 1, ISQM1, 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.Other matterThe comparative information included in the Sustainability statement of the Group for the financial year 2023 was not subject to an assurance engagement on sustainability information prepared in accordance with the Danish Financial Statements Act section 99a. Our conclusion is not modified in respect of this matter.Inherent limitations in preparing the Sustainability statementIn reporting forward-looking information in accordance with ESRS, management is required to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.Managementâs responsibilities for the Sustainability statementManagement is responsible for designing and implementing a process to identify the information reported in the Sustainability statement in accordance with the ESRS and for disclosing this Process as part of the General information. This responsibility includes:⢠understanding the context in which the Groupâs activities and business relationships take place and developing an understanding of its affected stakeholders;⢠the identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the 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, in accordance with the Danish Financial Statements Act section 99a, including:⢠compliance with the ESRS;⢠preparing the disclosures within the Environmental information of the Sustainability statement, in compliance with Article 8 of the Taxonomy Regulation;⢠designing, implementing and maintaining such internal control that management determines is necessary to enable the preparation of the Sustainability statement that is free from material misstatement, whether due to fraud or error; and⢠the selection and application of appropriate sustainability reporting methods and making assumptions and estimates that are reasonable in the circumstances.Auditorâs responsibilities for the assurance engagementOur objectives are to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability statement as a whole.As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement.Our responsibilities in respect of the Process include:⢠Obtaining an understanding of the Process but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process;⢠Considering whether the information identified addresses the applicable disclosure requirements of the ESRS, and⢠Designing and performing procedures to evaluate whether the Process is consistent with the Groupâs description of its Process, as disclosed in 1.4 Double materiality assessment of the Sustainability statement.Our other responsibilities in respect of the Sustainability statement include:⢠Identifying disclosures where material misstatements are likely to arise, whether due to fraud or error; and⢠Designing and performing procedures responsive to disclosures in the Sustainability statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.Summary of the work performedA limited assurance engagement involves performing procedures to obtain evidence about the Sustainability statement.The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise, whether due to fraud or error, in the Sustainability statement.In conducting our limited assurance engagement, with respect to the Process, we:⢠Obtained an understanding of the Process by performing inquiries to understand the sources of the information used by management; and reviewing the Groupâs internal documentation of its Process; and⢠Evaluated whether the evidence obtained from our procedures about the Process implemented by the Group was consistent with the description of the Process set out in 1.4 Double materiality assessment of the Sustainability statement.In conducting our limited assurance engagement, with respect to the Sustainability statement, we:⢠Obtained an understanding of the Groupâs reporting processes relevant to the preparation of its Sustainability statement (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 material information identified by the Process is included in the Sustainability statement;⢠Evaluated whether the structure and the presentation of the Sustainability statement are in accordance with the ESRS;⢠Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability statement;⢠Performed substantive assurance procedures on selected information in the Sustainability statement;⢠Evaluated methods, assumptions and data for developing material estimates and forward-looking information and how these methods were applied; and⢠Obtained an understanding of the process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Sustainability statement.Copenhagen, 4 February 2026DeloitteStatsautoriseret RevisionspartnerselskabBusiness Registration No. 33 96 35 56Anders Vad Dons Sumit SudanState-Authorised Public Accountant State-Authorised Public Accountantmne25299 mne33716</arr:AuditorsReportOnSubstainabilityReport>
<arr:AddresseeOfAuditorsReportOnSubstainabilityReports contextRef="ctx-1" id="f1__s10__8__234" xml:lang="en">To the stakeholders of Novo Nordisk A/S</arr:AddresseeOfAuditorsReportOnSubstainabilityReports>
<arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport contextRef="ctx-1" id="f1__s10__8__235" xml:lang="en">We have conducted a limited assurance engagement on the Sustainability statement of Novo Nordisk A/S (the âGroupâ) included in the Management Report (the âSustainability statementâ),for the financial year 1 January â 31 December 2025.</arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport>
<arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport contextRef="ctx-1" id="f1__s10__8__236" xml:lang="en">Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability statement is not prepared, in all material respects, in accordance with the Danish Financial Statements Act section 99a, 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 1.4 Double materiality assessment; and⢠compliance of the disclosures in 10. EU Taxonomy within the Other material topics information and EU Taxonomy â Contextual information, accounting policies and templates within the section Additional Sustainability statement information with Article 8 of EU Regulation 2020/852 (the âTaxonomy Regulationâ).</arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport>
<arr:EmphasisOfMatterSubstainabilityReport contextRef="ctx-1" id="f1__s10__8__237" xml:lang="en">Other matterThe comparative information included in the Sustainability statement of the Group for the financial year 2023 was not subject to an assurance engagement on sustainability information prepared in accordance with the Danish Financial Statements Act section 99a. Our conclusion is not modified in respect of this matter.Inherent limitations in preparing the Sustainability statementIn reporting forward-looking information in accordance with ESRS, management is required to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.</arr:EmphasisOfMatterSubstainabilityReport>
<arr:StatementOfAuditorsResponsibilitySubstainabilityReport contextRef="ctx-1" id="f1__s10__8__238" xml:lang="en">Auditorâs responsibilities for the assurance engagementOur objectives are to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability statement as a whole.As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement.Our responsibilities in respect of the Process include:⢠Obtaining an understanding of the Process but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process;⢠Considering whether the information identified addresses the applicable disclosure requirements of the ESRS, and⢠Designing and performing procedures to evaluate whether the Process is consistent with the Groupâs description of its Process, as disclosed in 1.4 Double materiality assessment of the Sustainability statement.Our other responsibilities in respect of the Sustainability statement include:⢠Identifying disclosures where material misstatements are likely to arise, whether due to fraud or error; and⢠Designing and performing procedures responsive to disclosures in the Sustainability statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.</arr:StatementOfAuditorsResponsibilitySubstainabilityReport>
<arr:SignatureOfSubstainabilityAuditorsPlace contextRef="ctx-1" id="f1__s10__8__239" xml:lang="en">Copenhagen</arr:SignatureOfSubstainabilityAuditorsPlace>
<arr:SignatureOfSubstainabilityAuditorsDate contextRef="ctx-1" id="f1__s10__8__240">2026-02-04</arr:SignatureOfSubstainabilityAuditorsDate>
<cmn:NameOfAuditFirmSubstainability contextRef="ctx-51" id="f1__s10__8__243" xml:lang="en">DeloitteStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirmSubstainability>
<cmn:NameOfAuditFirmSubstainability contextRef="ctx-50" id="f1__s10__8__241" xml:lang="en">DeloitteStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirmSubstainability>
<cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx-50" id="f1__s10__8__242">33963556</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
<cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx-51" id="f1__s10__8__244">33963556</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-50" id="f1__s10__8__245" xml:lang="en">Anders Vad Dons</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-51" id="f1__s10__8__248" xml:lang="en">Sumit Sudan</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx-50" id="f1__s10__8__246" xml:lang="en">State-Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx-51" id="f1__s10__8__249" xml:lang="en">State-Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx-50" id="f1__s10__8__247">mne25299</cmn:fIdentificationNumberOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx-51" id="f1__s10__8__250">mne33716</cmn:fIdentificationNumberOfSubstainabilityAuditor>
<gsd:NameOfSubmittingEnterprise contextRef="ctx-1" id="f1__s10__8__16" xml:lang="en">Novo Nordisk A/S</gsd:NameOfSubmittingEnterprise>
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<gsd:InformationOnTypeOfSubmittedReport contextRef="ctx-1" id="f1__s1__72__15">Annual report</gsd:InformationOnTypeOfSubmittedReport>
<cmn:TypeOfAuditorAssistance contextRef="ctx-1" id="f1__s1__72__16">Auditor's report on audited financial statements</cmn:TypeOfAuditorAssistance>
<gsd:ToolForPreparingTheXBRLInstanceDocument contextRef="ctx-1" id="f1__s1__72__17" xml:lang="en">ParsePort XBRL Converter</gsd:ToolForPreparingTheXBRLInstanceDocument>
<gsd:ReportingPeriodStartDate contextRef="ctx-1" id="f1__s1__72__20">2025-01-01</gsd:ReportingPeriodStartDate>
<gsd:ReportingPeriodEndDate contextRef="ctx-1" id="f1__s1__72__21">2025-12-31</gsd:ReportingPeriodEndDate>
<gsd:PrecedingReportingPeriodStartDate contextRef="ctx-1" id="f1__s1__72__22">2024-01-01</gsd:PrecedingReportingPeriodStartDate>
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<arr:TypeOfModifiedOpinionOnAuditedFinancialStatements contextRef="ctx-1" id="f1__s1__72__47">Opinion</arr:TypeOfModifiedOpinionOnAuditedFinancialStatements>
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