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| ifrs-full:Assets | 2025-12-31 | 6409000000 | dkk |
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<mrv:CorporateGovernanceReport contextRef="ctx-1" id="f0__s11__7__6" xml:lang="en">Corporate governanceGovernance structure NTG has a two-tier governance structure comprised of the Board of Directors and the Executive Manage-ment. The ultimate governing authority rests with the General Meeting.In terms of internal organisation, Group Management comprises the Executive Management, the divisional CEOs, and the Group CIO. The Executive Management is comprised of the Group CEO and Group CFO, as registered with the Danish Business Authority.The Board of Directors is responsible for the overall strategic management and organisation of the Groupâs activities as well as the Groupâs financial and material matters. The Board of Directors has established an audit, a remuneration, and a nomination committee focusing on preparatory tasks within the Board of Directorsâ areas of responsibilities.The Executive Management is responsible for NTGâs day-to-day management, including the compliance of NTG and its operations with applicable legislation, the Board of Directorsâ guidelines and instructions, includ-ing implementation of the strategy set by the Board of Directors, and for disseminating information on NTGâs operations to the Board of Directors.Further allocation of responsibilities between the Board of Directors and the Group Management is set out in the Rules of Procedure of the Board of Directors and in a set of management instructions issued by the Board of Directors to the Group Management.Board of DirectorsCompositionAccording to the Articles of Association, the Board of Directors must comprise not less than three and not more than eight members elected by the General Meeting for terms of one year. Board members are eligible for re-election.In 2025, Lene Borne Jørgensen was appointed to the Board of Directors, replacing Karen-Marie Katholm.The Board of Directors currently comprises seven members representing strong knowledge and expertise within all areas of NTGâs business and strategic focus areas, including the international transport sector in general, corporate governance, M&A, risk manage-ment, IT, accounting, and supply-chain management.The composition of the Board of Directors is intended to ensure that the Board of Directors is made up by diverse competency profiles enabling the Board of Directors to perform its duties in the best possible manner. The current Board of Directors is considered to have the right competencies supporting the long-term value creation for NTGâs shareholders. Reference is made to pages 35-36 for an overview of the current board membersâ individual competencies. Independence Six of the seven members of the Board of Directors are regarded as independent, according to the Danish Recommendations on Corporate Governance. Jørgen Hansen is the founder of NTG and was, until 2018, a member of the Executive Management in Nordic Transport Group A/S (the former parent company of the Group). As a result, he is not regarded as indepen-dent according to the Danish Recommendations on Corporate Governance.Board meetings in 2025The Board of Directors held 10 board meetings in 2025.The agendas and the topics for each of the ordinary meetings are based on the Board of Directorsâ annual wheel.In addition to the activities included in the annual wheel, the Board of Directors focused on supervising NTGâs continuous adaption to the unstable situation in the international freight markets in 2025. Board CommitteesThe Board of Directors has established three permanent committees for the purpose of assisting the Board of Directors in preparing decisions and submitting recom-mendations for the entire Board of Directors. Each com-mittee is governed by its own charter which describes the composition of the committee and its tasks, duties, and responsibilities. The Board of Directors takes the final decision on subjects prepared by the committees.Audit CommitteeThe Audit Committee comprises three members: Carsten Krogsgaard Thomsen (Chairman), Eivind Drach-mann Kolding, and Finn Skovbo Pedersen. The Audit Committee meets at least four times a year.The composition of the Audit Committee ensures that competencies and experience within financial accounting and internal controls are represented. The Committeeâs activities, tasks, and duties include mon-itoring of NTGâs financial reporting process, internal controls, IT, risk management, capital structure, and ESG reporting. The Committee is also responsible for ensuring independence and remuneration of the elect-ed external auditor as well as supervising the auditorâs non-audit services to NTG. The Audit Committee held four meetings in 2025.Remuneration CommitteeThe Remuneration Committee comprises three mem-bers: Eivind Drachmann Kolding (Chairman), Jørgen Hansen, and Jesper Præstensgaard. The Remuneration Committeeâs activities, tasks, and duties include prepa-ration of the Groupâs Remuneration Policy in accor-dance with section 139a of the Danish Companies Act, proposing remuneration and specific targets (KPIs) for performance-related incentive programmes and prepa-ration of the Remuneration Report in accordance with section 139b of the Danish Companies Act and NTGâs Remuneration Policy. The Remuneration Committee meets at least twice a year.Nomination CommitteeThe Nomination Committee comprises three members: Jørgen Hansen (Chairman), Jesper Præstensgaard and Eivind Drachmann Kolding. The Nomination Commit-teeâs activities, tasks, and duties include evaluation of the individual board membersâ competencies, assisting the Chairman of the Board of Directors in the annual evaluation process, making recommendations for potential new members to the Board of Directors, reviewing NTGâs policy on diversity, and assessing the structure, size, and composition of the Board of Direc-tors and the Executive Management. The Nomination Committee meets at least twice a year. The Nomination Committee held two meetings in 2025. Board evaluationsThe Board of Directors conducts annual self-evalua-tions. In accordance with the Recommendations on Corporate Governance, the evaluation focuses, inter alia, on the composition of the Board of Directors, the competencies of the Board of Directors, the func-tioning of the board committees, the efficiency of the Board of Directors, the individual board mem-bersâ contributions, and the role of the Chairman and Executive Management. The Chairman oversees the self-evaluation process and conclusions are presented to and discussed by the Board of Directors. The results of the evaluation related to the Executive Management are reviewed by the Chairman together with members of the Executive Management. Reporting on data ethicsInformation about data ethics in our Parent Company NTG Nordic Transport Group A/S, in accordance with sections 99d of the Danish Financial Statements Act, can be found on NTGâs website: Data ethics report. Recommendations on Corporate GovernanceNTG observes the recommendations on Corporate Governance. NTG complies with all recommendations and has prepared the statutory statement on Cor-porate Governance pursuant to section 107 b of the Danish financial statements act.Corporate Governance reportNTG complies with all recommendations on Corporate Governance. Meeting attendance and shareholdings in 2025Remuneration Nomination Board meetings Audit Committee Committee meetings Committee meetings Shareholding Number of shares Board of Directors Titleattendedmeetings attendedattendedattendedchanges in 2025end of 2025Eivind Drachmann Kolding Chairmanâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢ â¢â¢â¢â¢ â¢â¢ â¢â¢- 51,951Jørgen Hansen Deputy Chairmanâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢ â¢â¢ â¢â¢- 3,100,047*Finn Skovbo Pedersen Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢ â¢â¢â¢â¢- 20,529Jesper Præstensgaard Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢ â¢â¢ â¢â¢- 18,674Carsten Krogsgaard Thomsen Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢ â¢â¢â¢â¢- 5,294Louise Knauer Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢- -Lene Borne Jørgensen** Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢- -Karen-Marie Katholm*** Board memberâ¢â¢â¢â¢â¢â¢â¢â¢â¢â¢- 4,507⢠Attended ⢠Not attended ⢠Not a member at the time* In addition, Jørgen Hansen controls 150,000 voting rights.** Appointed at the AGM in 2025 and has attended all meetings since taking up the position.*** Stepped down at the AGM in 2025 and attended all meetings up to the time of departure.</mrv:CorporateGovernanceReport>
<mrv:StatementOfPolicyForDataEthics contextRef="ctx-1" id="f0__s11__7__7" xml:lang="en">Reporting on data ethicsInformation about data ethics in our Parent Company NTG Nordic Transport Group A/S, in accordance with sections 99d of the Danish Financial Statements Act, can be found on NTGâs website: Data ethics report.</mrv:StatementOfPolicyForDataEthics>
<mrv:SustainabilityReport contextRef="ctx-1" id="f0__s11__7__9" xml:lang="en">SustainabilitystatementGeneral informationESRS 2 SBM-1 Strategy, business model and value chainSustainability at NTGSustainability is an integral part of NTGâs long-term strategy and daily operations. As a global transport and logistics group, we recognise our responsibility to operate in a manner that minimises environmental impact, safeguards the wellbeing of people, and promotes responsible business conduct across our value chain. NTGâs decentralised business model empowers each company within the Group to take ownership of its sustainability performance while adhering to Group-level policies, principles, and expectations. This approach enables us to remain agile and close to customers while ensuring consistent standards and accountability.Our sustainability work is guided by international norms and frameworks, including the principles of the UN Global Compact, the ILO Core Conventions, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. These standards shape our policies, due diligence processes, and risk management practices, ensuring that we address the most material impacts of our operations.ESRS 2 Strategy and business modelOur environmental focus is on reducing greenhouse gas emissions, improving data transparency, and collaborating with customers and suppliers to advance low and zero emission transport solutions. We continue to strengthen our emissions data and work to support more efficient logistics across the value chain.On the social front, we prioritise safe, inclusive, and fair working conditions. We uphold labour rights, ban on child labour, promote employee development, and work to ensure responsible practices within our supply chain, particularly regarding working conditions and the prevention of forced labour.Strong governance underpins our approach. NTG maintains a robust compliance framework covering anti-corruption, whistleblower protection, sanctions, data protection, and responsible procurement. Oversight by the Board Directors and Executive Management ensures accountability and continuous improvement.As NTG continues to grow, we remain focused on strengthening transparency, enhancing data quality, and embedding sustainability more deeply into decision-making across the Group. Our ambition is to contribute to a more responsible and resilient transport and logistics sector while creating long-term value for our customers, employees, and society. Please find detailed split of employees per country on p. 80.Climate and Environment related goalsReducing environmental impact across our operations and value chain is a key priority. NTG has committed to setting emission reduction targets aligned with the Science Based Targets initiative (SBTi) to limit global warming to 1.5°C and achieve net-zero emissions by 2050, in line with the Paris Agreement. Achieving these goals requires strong collaboration with customers and suppliers to reduce carbon emissions across our network. Further details are provided in the Environmental and Climate Change (E1) section.Social related goalsAs a people-driven business, NTG is committed to creating a safe, inclusive, and inspiring workplace. We aim to reduce work-related injuries and lost days while fostering diversity and equal opportunities. Targets include: · The Board of Directors aims to ensure that at least 40% of its members are from the underrepresented gender by 30 June 2026. · For management levels reporting directly to the Executive Management, the aim is to achieve at least 30% representation of the underrepresented gender by 2028.Additional diversity targets are outlined in the Social and Employees (S1) section.Governance related goalsNTG complies with all applicable laws and regulations across jurisdictions. To manage compliance risks, we have implemented a Legal Compliance Program covering anti-corruption, trade controls, competition law, and data privacy. Our Code of Conduct guides ethical decision-making, and all salaried employees must complete annual training.We also require suppliers to adhere to our Supplier Code of Conduct, which addresses human rights, labour standards, anti-corruption, and environmental responsibility. Compliance is monitored through annual audits, spot checks, and internal reviews. More details are provided in the Governance (G1) section.ESRS 2 SBM-2 Interests and views of stakeholdersNTGâs stakeholders are fundamental to our services, operations, and long-term success. Understanding their perspectives and priorities enables us to shape our strategy and business model effectively. This includes developing decarbonisation solutions to reduce customersâ supply chain emissions, fostering an inclusive and engaging workplace that supports our growth strategy, and ensuring integrity in all markets where we operate.We identify and map NTGâs key stakeholders and maintain regular engagement with them, some more frequently than others, always with the purpose of gathering insights into their interests and views on sustainability and our business activities.Stakeholder perspectives on sustainability form the foundation for identifying potential material topics, which are assessed through NTGâs double materiality process. This process is described in detail in IRO-1 of this report. In Table SBM-2 â Interests and views of stakeholders, we disclose our most important stakeholder groups, the methods of engagement, and the value derived from these interactions.Based on the outcome of our engagements with key stakeholders their interests and views are reflected in our double materiality process.NTGâs stakeholders and engagementESRS 2 SBM-2 Interests and views of stakeholdersEmployees Organisation of engagement · Annual employee satisfaction surveys and additional internal surveys to monitor working conditions, motivation, and improvement areas · Daily dialogue between employee and manager, incl. personal development · Employee Health & Safety representativesPurpose of engagementsEmployees are the backbone of NTG's business strategy as a service provider of transports. It is important to ensure high job satisfaction and engagement which is achieved when employees' perspectives on working life are included in the way NTG operates.Examples of outcomes from the engagements · NTG's management obtain relevant and business critical feedback from employees on customers, suppliers and business operations. · Adaptation and optimisation of employees working conditions and possibilities. · Improved health and safety performance.SuppliersOrganisation of engagement · Formal engagement through contracts and negotiations, covering the relevant terms and conditions, performance requirements · Supplier audits · Daily operational basis â road suppliers · Through partnerships â air and ocean suppliersPurpose of engagementsNTG is highly dependent on its suppliers and its employees for several important operations in NTG's value chain. The supplier and its employees must be able on behalf of NTG to handle goods and comply with agreed customer-spe-cific quality criteria and procedures and the NTG's Supplier Code of Conduct. In addition, suppliers must be able to handle and mitigate any deviations in cooperation with NTG and/or the customer as well as any other suppliers in the value chain.Examples of outcomes from the engagements · Compliance of NTGâs Code of Conduct for Suppliers. · Cooperation with suppliers result in low- carbon solutions can be offered to NTGâs customers.CustomersOrganisation of engagement · Dialogue on a daily operational basis · Accounting teams conduct customer reviews · Dialogue on possibilities for carbon emission reductions · Reporting carbon emissions to customersPurpose of engagementsNTG's transport services conducts a share of customers scope 3 GHG emissions that becomes a disclosure requirement for more and more customers. Customers demand that NTG can comply with their ESG policies and other ESG requirements related to the performance of NTG's services.Examples of outcomes from the engagements · Dialogue with customers forms the basis for developing alternative services based on decarbonising solutions. · Decarbonising solutions reduces customers supply chain emissions and NTGâs scope 3 emissions.Investors, financial institutions, andfinancial analystsOrganisation of engagement · On regular announced meetings by NTG management such as investor calls and roadshows · Requested meetings arranged by investorsPurpose of engagementsThe management of NTG communicates to investors the financial status of NTG, incl. on the development of NTG's work on sustainability.Investors request individual meetings as they wish to understand NTG's position and actions on sustainability topics.Examples of outcomes from the engagements · Dialogue with this group of stakeholders provides information to NTG on their sustainable interests, expectations and requirements. · ESG ratings and basic for improvement. · Securing external financing options and capital allocation.Public authorities and regulatorsOrganisation of engagement · Performed through regular dialogue on tax, VAT, permits on customers declarations · Indirectly via membership of trade associationsPurpose of engagementsNTG follows updates of regulations and legislation issued by public authorities to comply or advise on compliance for customers and suppliers.Support the operation of a stable and healthy business, enabling NTG to conduct its activity in compliance with applicable laws and regulations, to generate profits and pay correct taxes. Examples of outcomes from the engagements · Aligning logistic service model and strategy. · Value creation and risk mitigation from compliance. · Increased awareness and operational alignment with regulatory climate and emission-reduction targets, influencing NTGâs ESG strategy and long-term planning.ESRS 2 SBM-3Material impacts, risks and opportunities and their interaction with strategy and businessOutput from the materiality assessmentThe 2025 review of the double materiality assessment (DMA) resulted in adjustments to the material impacts, risks and opportunities (IROs), including the removal of one actual negative impact and the identification of a new material risk within the âWorkers in the Value Chainâ topic.The material IROs identified during the materiality assessment described in the table on the next page are presented alongside the topical ESRS E1 Climate change, E2 Pollution, S1 Own workforce, S2 Workers in the value chain and G1 Business conduct in this sustainability statement. The material IROs current and anticipated effects are managed through NTG's strategy and business model. Material impacts, risks and opportunities are managed through specific policies, actions, targets and metrics which all also are addressed and described further in each topical section in the statement.Location in IROvalue chain Time horizonESRS E1 â Climate changeâ¶Emissions from value chain operationsNTG arranges low to medium carbon emitting transport Actual â â â â â âoperations performed by suppliers on behalf of customers.negative impactâ·Energy consumption in own operationsNTG's own assets consumes energy resources Actual â â â âin order to perform its services.negative impactâ¸Low carbon transports and servicesCustomers have a growing interest in sustainable fuels and Opportunityâ â â â â âdemands for zero/low carbon transports and services.ESRS E2 - Pollutionâ¹Air pollutantsNTG's transport activities via the value chain generates Actual â â â â â âemissions, some of which are also air pollutants.negative impactLocation in IROvalue chain Time horizonESRS S1 - Own workforceâºHealth and safetySome groups of employees have a risk of being exposed Actual â â â âto injuries and other health risks in the workplace.negative impactâ»DiversityIncreasing focus on gender diversity and showcasing data on Riskâ â â âa diverse workforce poses a risk to NTG if not complying.â¼PrivacyIn case NTG is unable to protect collected data Actual â â â âfrom unauthorised access or misuse.negative impactESRS S2 - Workers in value chainâ½Forced labourSuppliers in some countries could force its employees to violate Riskâ â â â ârules and conditions of work, which could present a risk to NTG.ESRS G1 - Business conductâ¾Prevention and detection including trainingDespite global anti-corruption laws, certain areas of NTG's or-Riskâ â â â â âganisation are at higher risk of corruption and bribery as they operate in countries which have higher risks, including the use of facilitation payments for permits, cargo clearance etc. ESRS 2 Basis for preparationESRS 2 BP-1 General basis for preparation of sustainability statementsThe Sustainability statement has been prepared on the same consolidated basis as NTGâs 2025 financial statements and covering same period from 1 January 2025 to 31 December 2025. The sustainability statement has been prepared in compliance with the EUâs Corporate Sustainability Reporting Directive (CSRD) and the requirements of the European Sustainability Reporting Standards (ESRS) and the EU Taxonomy. The consolidated quantitative ESG data comprises the Parent Company NTG Nordic Transport Group A/S, and all subsidiaries controlled by NTG Nordic Transport Group A/S. Acquired activities in the reporting period is included in the sustainability reporting from the closing date of the transaction.All quantitative ESG data is consolidated according to the principles outlined above, unless otherwise specified in the accounting policy accompanying each reported data point in the tables within sections Environmental, Social, and Governance information.The double materiality assessment process outlined in IRO-1 contains impacts, risks, and opportunities throughout our entire value chain, both upstream and downstream. The reporting boundary encompasses NTGâs value chain from the initiation of transport services for customer goods through to final delivery. Upstream activities such as raw material extraction and product manufacturing, as well as downstream activities related to the end-use of transported goods, are considered outside the scope of this disclosure.More details on NTGâs policies, actions, targets, and metrics can be found in the sections related to the topical standards. There are no omitted disclosures on information corresponding to intellectual property, know-how or the results of innovation in the sustain-ability statement nor omitted disclosures regarding impending developments or ongoing negotiations.ESRS 2 BP-2 Disclosures in relation to specific circumstancesKey accounting estimates and judgementsIn presenting the 2025 sustainability statement, NTG utilises assessments and estimates for reporting certain data points where data is not available. These estimates and assumptions are regularly reassessed based on experience, advancements in ESG reporting, and various other factors. NTG keeps the same definition and calculation of metrics over time. Should any changes in estimates appear, they would be duly recognised in the period when the revision occurs and restated comparative figures provided. Additionally, we apply judgements when implementing the accounting policies.NTG seeks to report data as accurately and reliably as possible by using primary measurement data and by standardising emissions calculations with emission factors drawn from internationally recognised industry standards. Our measurement approach follows the GHG Protocol and applies activity-based, spend-based, or hybrid methods, depending on the data available.To minimise uncertainties in our calculations, we do not use indirect data sources such as industry benchmarks, judgement-based estimates, or sector averages.The quantification of attributable avoided emissions is based on NTGâs informed judgements and applicable assumptions.For a more detailed information on the key estimates, judgements, and assumptions used, please refer to the pages containing the quantitative ESG data on NTG's Scope 1, 2 and 3 GHG emissions on page 62.Changes in preparation and presentation of sustainability informationNTG has revised its methodology to include GHG emissions from additional relevant market-based Scope 2 and Scope 3 categories, thereby enhancing Restatement due to revised dataDifference from Restated 2024 ESRS ID Reasons for restatement Units2024 baselinenumbersE1-6_10 Gross market-based Scope 2 greenhouse gas emissions, p. 63 Revision of GHG emission accounting methodology tonnes COe 3,421 3,4212E1-6_11 Gross Scope 3 greenhouse gas emissions, p. 63 Revision of GHG emission accounting methodology tonnes COe 242,025 822,3482E1-6_11 Gross Scope 3 greenhouse gas emissions, p. 63 Category 4 GHG emissions restated as well-to-wheel. tonnes COe 195,463 775,7862E1-6_13 Total GHG emissions market-based, p. 63 Revision of GHG emission accounting methodology tonnes COe 833,354 833,3542E1-6_30 GHG emissions revenue intensity â Location-based, p. 63 Revision of GHG emission accounting methodology tonnes COe/DKKm 88.9 88.92E1-6_31 GHG emissions revenue intensity â Market-based, p. 63 Revision of GHG emission accounting methodology tonnes COe/DKKm 89.1 89.12S1-14_05 Rate of recordable work-related accidents for own workforce, Rate per million p. 85 Improved data qualityworking hours 0.7 5.2transparency regarding its climate-related impacts. As a result, NTGâs 2024 GHG emissions have been restated in datapoints E1-6_10, E1-6_11 and E1-6_13.Consequently, the 2024 data reported in E1-6_13 are restated as Well-to-Wheel GHG emissions and E1-6_30, E1-6_31 restated as total GHG emissions revenue intensity. Finally, datapoint S1-14_05 has been restated due to improved data quality. See more details in the table above.Incorporation by referenceNTG has adopted the ESRS âIncorporation by Referenceâ approach to enhance the narrative. As a result, certain disclosure requirements have been included in other sections of the Annual Report and thus outside the Sustainability statement. These disclosure requirements include: · SBM-1 â Information related to NTGâs business model and value chain, services offered and customer groups on p. 6 + 10. · SBM-1 - Information related to significant markets and total revenue on p. 109. · GOV-1 - Information related to the Board of Directors general composition, diversity and independency on p. 32-36. · GOV-1 - Information related to disclosure of permanent committees and composition established by the Board of Directors on page 32-34 of the Management Review. · GOV-1 - Information related to disclosure of expertise of Board of Directors, included under sections "Relevant Skills and Experience" subheadings on page 35-36 of the Management Review. · E1-5, E1-6 - Net revenue on p. 18, Condensed income statement.Use of phase-in provisions Due to the extension for all entities subject to the first wave of CSRD reporting, the transitional provision in ESRS 1, paragraph 137 allowing for phasing-in certain material datapoint disclosures has been applied, more specifically encompassing E1 (E1-9), and S1 (S1-7, S1-11) and S2.ESRS 2 Sustainability governanceESRS 2 GOV-1 The role of the administra-tive, management and supervisory bodiesGovernance StructureNTG operates under a two-tier governance model consisting of the Board of Directors and the Executive Management, with ultimate authority vested in the Annual General Meeting.Group ManagementThe internal governance framework includes the Executive Management, divisional CEOs, and Group CIO. The Executive Management, as registered with the Danish Business Authority, comprises the Group CEO and Group CFO.Board of DirectorsThe Board of Directors holds responsibility for the Groupâs overall strategic direction, organisational framework, and oversight of financial and material matters. To strengthen governance, the Board of Directors has established three committees - Audit, Remuneration, and Nomination - which perform preparatory work within their respective areas of responsibility. For details on committee roles and membership, we refer to the Corporate Governance Statement in the Annual Report, p. 32â34. NTG has no representation of employees or other workers in the Board of Directors.Executive ManagementThe Executive Management is accountable for NTGâs day-to-day operations, ensuring compliance with applicable legislation and adherence to the Board of Directorâs guidelines and strategic directives. This includes implementing the strategy set by the Board of Directors and providing timely and accurate information on NTGâs activities. The division of responsibilities between the Board of Directors and Group Management is defined in the Rules of Procedure for the Board of Directors and in management instructions issued by the Board of Directors.Oversight of sustainability and ESGThe Board of Directors and Executive Management hold ultimate responsibility for NTGâs sustainability and ESG governance. This includes setting policies, defining strategic objectives, and overseeing ESG-related risks such as climate impacts and other material sustainability risks.Execution of ESG strategies and activities is delegated to NTGâs Legal, Compliance, and ESG functions, under the supervision of the Group CFO. These functions collaborate closely with local management where needed, monitor progress, and collect internal and external data, supported by other relevant functions across the Group.to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesThe Board of Directors and Executive Management hold overall responsibility for defining NTGâs business strategy and risk management framework, including sustainability and ESG-related matters. The Board of Directors receives regular updates from Executive Management on NTGâs sustainability approach, performance, and material impacts, risks, and opportunities. It also reviews and approves the annual Sustainability statement.The implementation of the strategy and the execution of the agreed activities are delegated to legal, compliance and ESG functions in NTG under the supervision of our Group CFO. NTGâs organisation is characterised by a flat hierarchy and short communication lines, enabling rapid escalation and resolution of emerging sustainability issues. Weekly operational and strategic meetings between the CFO and ESG function ensure continuous monitoring and progress on implementation.At least annually, the Audit Committee and Board of Directors review the results of NTGâs double materiality assessment, including methodology and identified material impacts, risks, and opportunities.Risk assessment is embedded in NTGâs recurring strategic analyses. The Board of Directors oversees the Groupâs overall risk management, while the Audit Committee monitors and evaluates the risk management framework and provides recommendations. Executive Management is responsible for designing and maintaining the Groupâs risk management processes. Sustainability considerations are fully integrated into NTGâs risk assessment procedures.ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemesNTG offers various incentive programmes for management, partners, and key employees. Among these, the Short-Term Incentive Programme (STIP) for Executive Management is the only programme directly linked to sustainability performance.The STIP is an annual, cash-based bonus tied to individual KPIs for each member of Executive Management. One of these KPIs relates specifically to sustainability and accounts for 10% of the total STIP. This sustainability KPI covers a range of activities, from implementing projects aimed at reducing emissions across NTGâs operations to preparing reports on selected sustainability topics relevant to NTG.The Board of Directors evaluates achievement of the sustainability KPI annually, based on the completion and recognition of agreed projects during the performance period.ESRS 2 GOV-4 Statement on due diligenceESRS 2 GOV-2 Information provided Core elements of due diligence Sections in the Sustainability statement PageEmbedding due diligence in governance, Strategy and business modelp. 44-45 strategy and business modelSustainability governancep. 51-54Engaging with affected stakeholders in Strategy and business modelp. 44all key steps of the due diligenceSustainability governancep. 51-53ESRS 2 IRO-1p. 54E1.IRO-1,p. 59 E2.IRO-1p. 69 S1-2,p. 80S2p. 88SBM3, G1p. 91Identifying and assessing adverse impacts Strategy and business modelp. 44-45 ESRS 2 IRO-1p. 54E1.SBM-3p. 60S1.SBM-3p. 78S2p. 88G1.SBM-3p. 89Taking actions to address those adverse impacts E1-1p. 58ESRS 2 MDR-A, E1-3p. 61ESRS 2 MDR-A, S1-4p. 79S2p. 88G1-1p. 94G1-3p. 95Tracking the effectiveness of these MDR-T, E1-4p. 62efforts and communicatingMDR-T S1-5p. 79G1-4p. 95ESRS 2 Risk management and internal controls in sustainability reportingESRS 2 GOV-5 Managing Risks in Sustainability ReportingNTG recognises that accurate and reliable sustainability reporting is critical for transparency and compliance. However, like all large organisations, our reporting processes are susceptible to the risk of material misstatement, primarily due to human error or incomplete data. This risk is further amplified by NTGâs rapid growth through acquisitions, as newly acquired companies integrate into NTGâs Group-wide systems and processes throughout the year. To address these challenges, NTG has established a comprehensive framework of processes and controls designed to mitigate these risks and ensure the integrity of our sustainability data.Governance and Data ManagementResponsibility for maintaining a consolidated sustainability data model rests with NTGâs Group CFO. This is achieved through a dedicated reporting platform that collects, validates, and consolidates data from across the NTG Group. The process is supported by detailed internal guidelines and control procedures that define how sustainability data is managed and reported. These measures ensure consistency and accuracy across all reporting entities.All data presented in the Sustainability statement is governed by NTGâs accounting policies. Where estimates are required in data calculations, the policies clearly outline the methodology applied to each data point, ensuring transparency and comparability.Risk management and internal controlsRisk assessments are embedded within NTGâs data-collection processes to prevent misleading information, statements, figures, or conclusions arising from inaccurate or incomplete data. Risks are defined as events that may affect the audit objectives - completeness, accuracy, and consistency - as set out in ESRS 1, Appendix B âQualitative characteristics of informationâ. As part of the data-collection process, risks are identified for each relevant data point and described in relation to the audit objectives, together with the corresponding mitigation measures.The risk-assessment methodology applied to the Sustainability statement identifies where material misstatements may occur within the data-collection process. A comprehensive risk mapping and assessment has been carried out for all key data points, with mitigation actions and quality controls set out for each identified risk.The mitigation strategy is designed to maintain a robust control environment, with a strong focus on preventive controls to identify risks at the earliest possible stage. Both manual and automated controls are in operation, and NTG aims to increase the level of automation over time.Risk-control activities are undertaken in connection with periodic internal and external reporting. Audits are conducted by both internal and external auditors, following an approach consistent with the financial audit process. The results of the limited assurance process including any observations or identified risks are reported to NTGâs Group CFO who aligns identified risks with the Audit Committee.Automation, Transparency, and StandardisationTo further strengthen data integrity, NTG has implemented automated processes for data-collection and consolidation. These systems provide full transparency and traceability, enabling stakeholders to follow the data flow from source to final report. In addition, NTG has standardised key elements of its reporting framework, including terminology, formulas, and critical variables such as emission factors. These standards are aligned with the Greenhouse Gas Protocol (GHG), ensuring compliance with internationally recognised methodologies.Compliance with ESRS and External AssuranceNTGâs sustainability reporting framework is aligned with the European Sustainability Reporting Standards (ESRS). Accounting principles based on ESRS requirements have been adopted for all sustainability data disclosed in the Sustainability statement. To provide additional confidence to stakeholders, NTG engages an independent external auditor to perform limited assurance on the Sustainability statement in accordance with the requirements of the Corporate Sustainability Reporting Directive (CSRD) and ESRS. For further details, please refer to the auditorâs assurance statement included in this report.ESRS 2 IRO-1Processes to identify and assess material IRO´sThe double materiality assessment (DMA) was reviewed and updated during the year, informed by insights gained from the first year of reporting under the ESRS. While the review resulted in certain adjustments, it did not materially change the overall areas of focus. Proposed alterations to impacts, risks and opportunities were initially developed based on internal subject-matter expertise, a deeper understanding of the ESRS requirements, publicly available benchmarks and analyses of CSRD reports, and insights from an internal peer comparison. NTG applies time horizons consistent with those prescribed in ESRS 1, section 6.4. The process followed a four-step, iterative methodology:â¶Step: Context Analysis and Identification of drivers. To identify the drivers behind our IROs, we began by analysing the context of NTGâs business. This included mapping our business model and value chain, covering business relationships, activities, products and services, and geographic locations. The purpose was to under-stand how NTGâs operations could affect or be affected by people and the environment.To broaden the scope of our analysis, we conducted extensive desk research. This included reviewing the legal landscape, relevant ESG standards, sector-specific frameworks, academic research, media coverage, and other sources. These inputs helped us identify external factors that could influence NTGâs sustainability-relat-ed impacts, risks, and opportunities.â·Step: Identification of actual and potential IROs.Next, we engaged relevant internal sub-ject-matter experts from both operational units and Group functions. These experts possess deep industry knowledge and maintain ongoing dialogue with stake-holders, enabling them to act as proxies for external stakeholder input when necessary. Their insights were critical in identifying actual and potential positive and negative impacts, as well as risks and opportunities.The identified IROs were mapped against the list of matters presented in ESRS 1, AR 16, and supplemented with enti-ty-specific matters where relevant. This ensured that our assessment was com-prehensive and aligned with regulatory requirements.â¸Step: Assessment of Materiality.We then assessed the materiality of each identified impact, risk, and opportunity. For impacts, materiality was evaluated based on severity (including scale, scope, and irremediability) and likelihood. Irremediability was excluded for positive impacts, and likelihood was excluded for actual impacts. For risks and opportuni-ties, financial materiality was assessed based on financial magnitude and likeli-hood of occurrence.A five-point scale was used to score both impact materiality and financial materi-ality. A combined score was calculated, and topics scoring above 2.5 on both dimensions were considered material to NTG. For risks, we applied the same approach and scale used in NTGâs overall risk management framework, ensuring sustainability-related risks are prioritised alongside other business risks.The final scores were derived from a com-bination of assumptions, NTGâs internal data, third-party quantitative data (where available), and qualitative insights from stakeholder engagement. Location-spe-cific factors were considered where relevant. The process also incorporated perspectives from silent stakeholders, such as nature, through input from NGOs. Additional sources included pre-existing records, self-assessment results, docu-ment analysis, and academic research.The results of the DMA, including the list of material IROs, were presented to NTGâs Executive Management and Board of Directors for review, input, and approval. These bodies hold ultimate responsibility for NTGâs business strategy and risk man-agement, including sustainability matters.â¹Step: Determining Disclosure Requirements.Finally, based on the list of material matters identified, we consulted ESRS 2 and relevant topical standards to determine disclosure requirements and data points for gap analysis and final reporting. The material matters are presented on page 48.Omitted TopicsAll ESRS topics has been assessed and some of them were deemed immaterial, including:E3 â Water and marine resources NTG has no business activities that directly rely on water consumption. Water use at NTGâs facilities is limited to drinking and sanitary purposes in its daily operations.E4 â Biodiversity and ecosystems NTGâs business activities, as well as certain activities within its value chain, can have physical impacts on nature, biodiversity, and ecosystems. This is primarily due to the reliance on fossil fuels for most transport operations, which generates GHG emissions and contributes to climate change, thereby affecting natural environments and biodiversity. At this stage, these impacts have not been assessed as material for NTG.E5 â Circular economy NTG assessed its resource use and circular-economy material topics by identifying the main waste streams associated with transport and logistics activities. Packaging materials - particularly plastics and cardboard from warehouse operations - represent the most relevant waste types. Although certain service activities generate resource inflows and outflows, including packaging and materials used in reloading and repacking, these do not constitute significant resource flows at Group level, and the impact has not been assessed as material.ESRS 2 IRO-2Content index of ESRS disclosure requirements ESRS 2 IRO-2 Disclosure Requirement IRO-2 â Disclosure Requirements in ESRS covered by the undertakingâs Sustainability statement Sustainability statement List of material disclosure requirementsreference pageESRS 2 General disclosuresSBM-1 Strategy, business model and value chain Page 44SBM-2 Interests and views of stakeholders Page 46SBM-3 Material impacts, risks and opportunities and their interaction with Page 47strategy and business modelBP-1 General basis for preparation of sustainability statements Page 45BP-2 Disclosures in relation to specific circumstances Page 49GOV-1 The role of the administrative, management and supervisory bodies Page 51GOV-2 Information provided to and sustainability matters addressed by the Page 52undertaking's administrative, management and supervisory bodiesGOV-3 Integration of sustainability-related performance in incentive schemes Page 52GOV-4 Statement on due diligence Page 52GOV-5 Risk management and internal controls over sustainability reporting Page 53IRO-1 Description of the processes to identify and assess material impacts, Page 59risks and opportunitiesIRO-2 Disclosure requirements in ESRS covered by the undertaking's Page 55sustainability statementSustainability statement List of material disclosure requirementsreference pageE1 Climate changeE1-1 Transition plan for climate change mitigation Page 58E1 GOV-3 Integration of sustainability-related performance in incentive schemes Page 52E1 SBM-3 Material impacts, risks and opportunities and their interaction with Page 60strategy and business modelE1 IRO-1 Description of the processes to identify and assess material climate Page 59related impacts, risks and opportunitiesE1-2 Policies related to climate change mitigation and adaptation Page 61E1-3 Actions and resources in relation to climate change policies Page 61E1-4 Targets related to climate change mitigation and adaptation Page 62E1-5 Energy consumption and mix Page 66E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions Page 62E1-9 Anticipated financial effects from material physical and transition risks Page 49and potential climate-related opportunitiesE2 PollutionE2 IRO-1 Description of the processes to identify and assess material pollution-Page 69related impacts, risks and opportunitiesE2-1 Policies related to pollution Page 69E2-2 Actions and resources related to pollution Page 69E2-3 Targets related to pollution Page 69E2-4 Pollution of air, water and soil Page 69Sustainability Statement List of material disclosure requirementsreference pageS1 Own workforceS1 SBM-3 Material impacts, risks and opportunities and their interaction with Page 78strategy and business modelS1-1 Policies related to own workforce Page 79S1-2 Processes for engaging with own workforce and workers' Page 80representatives about impactsS1-3 Processes to remediate negative impacts and channels for own Page 80workforce to raise concernsS1-4 Taking action on material impacts on own workforce, and approaches to Page 79managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actionsS1-5 Targets related to managing material negative impacts, advancing Page 79positive impacts, and managing material risks and opportunitiesS1-6 Characteristics of the undertaking's employees Page 80S1-9 Diversity metrics Page 82S1-14 Health and safety metrics Page 85 S1-17 Incidents, complaints and severe human rights impacts Page 87S2 Workers in value chainESRS 2 General Brief description of business model, policies, actions and targets Page 88disclosures, relevant to the material topic.paragraph 17Sustainability Statement List of material disclosure requirementsreference pageG1 Business conductG1 GOV-1 The role of the administrative, supervisory and management bodies Page 92G1 IRO-1 Description of the processes to identify and assess material impacts, Page 91risks and opportunitiesG1-1 Corporate culture and business conduct policies and corporate culture Page 94G1-3 Prevention and detection of corruption and bribery Page 95G1-4 Confirmed incidents of corruption or bribery Page 95Environment informationESRS E1Climate changeSustainability strategyNTG is an asset-light freight forwarder providing customised road, rail, air, and ocean transport solutions. We coordinate and optimise supply chains in close cooperation with our transport suppliers rather than operating our own fleets. Consequently, the majority of our carbon footprint arises indirectly through supplier-provided transport services. Under the Greenhouse Gas Protocol, these emissions are classified as Scopeâ¯3.E1-1 Transition plan for climate change mitigationNTG has committed to set our emission reduction targets in line with the Science Based Targets initiative (SBTi) to limit global warming to 1.5°C towards 2030 and reach net-zero emissions by 2050 in line with the most recent climate research and recommendations and Paris Agreement goals. Already in 2023 NTG completed calculations of relevant emissions according to the Greenhouse Gas Protocol from our 2022 activities that is required by SBTi before presenting targets for reduction. Further, we have worked on plans to reduce emissions from various direct and indirect sources.NTG has in 2025 prepared its GHG emissions accounts and sustainability strategy to enable future validation of science-based reduction targets by the Science Based Targets initiative (SBTi). The process has focused on building a complete, high-quality emissions baseline and integrating decarbonisation into the Groupâs strategic planning. NTG has established a consolidated GHG inventory in line with the GHG Protocol, covering Scope 1 and Scope 2 emissions from its own operations and Scope 3 emissions from its value chain, with particular emphasis on transportation and distribution.In 2026 NTG will align its sustainability strategy with a long-term, Paris-aligned decarbonisation pathway. This includes defining levers for emissions reduction - such as modal shift, consolidation, fuel efficiency measures, and increased uptake of low-carbon transport solutions provided by carriers - while integrating climate considerations into procurement processes and commercial decision-making. The strategy also embeds forward-looking scenario considerations and interim milestones to support credible target-setting. This work should result in NTG being able to present its reduction targets to SBTi during 2026. This will also constitute NTG's transition planThese efforts ensure that NTG is organisationally, meth-odologically, and strategically prepared for submitting reduction targets to the SBTi for formal validation.How we pursue our goalsAs most of NTGâs emissions are indirect and classified as Scopeâ¯3 under the Greenhouse Gas Protocol and the SBTi, progress towards a 1.5°C pathway relies on close cooperation with both customers and suppliers. We therefore focus on targeted initiatives that reduce value-chain emissions and encourage the uptake of low-carbon transport solutions.Optimising customer supply chainsAs an asset-light freight forwarder, NTG works with customers to reassess and improve existing transport setups. Using tailored emissions reports and detailed assessments, we identify efficiency opportunities that often require only minor adjustments. Selecting the most appropriate transport mode for each shipment is a key lever, balancing cost, lead time, and carbon performance. Where feasible, we explore slower or alternative modes to reduce emissions.Bio-fuels â a decarbonising alternativeNTG collaborates with customers and carriers to expand the use of locally available, lower-carbon alternatives to fossil fuels. Bio-based fuels, already applicable across several transport modes, can provide an immediate reduction in emissions where supply and certification allows.Battery electric vehiclesTogether with suppliers, we continue to assess routes where battery electric vehicles (BEVs) are operationally viable. Although capacity remains limited and costs may be higher than fossil fuelled options, BEVs represent a growing opportunity to reduce emissions on suitable lanes.ESRS E1Climate-related impacts, risks and opportunitiesNTG has streamlined its stakeholder assessment to strengthen our approach to double materiality in line with ESRS requirementsE1 IRO-1 Description of the processes to identify and assess material climate related impacts, risks and opportunities Our assessment of actual and potential impacts, risks, and opportunities is based on structured engagement with key stakeholders and insights gathered through an established dialogue.To ensure robust analysis, we also draw on internal subject-matter experts who act as proxies for affected stakeholders. Their deep operational and functional knowledge, combined with ongoing interaction with stakeholder groups, enables a well-informed evaluation of NTGâs sustainability impacts, including climate-related effects.Stakeholder input, together with expert assess-ments, supports the identification and prioritisa-tion of material sustainability matters. Building on this foundation, NTG has analysed relevant scenarios to deter-mine climate-related physical and transition risks and opportunities across both our own opera-tions and our value chain. The result is that NTG is not exposed to transitional or physical scenario analysis. Further identification and assessment of physical and transitional risks and opportunities will be included in future transistion plan.ESRS 2 E1KPIs 2025 Progression Read moreReduction of GHG Working on roadmap NTG has committed to set our emission reduction targets Page 62emissionsfor reaching targetsin line with SBTi to limit global warming to 1.5°C and reach net-zero emissions by 2050. We are exploring different technologies in close collaboration with our sub vendors.Optimise Made more than 250 To ensure transparency towards the customers, we have set Page 61customer customised carbon up a framework to report on customised carbon emissions supply chains in emission reportsto each of our customers who wants it. Based on the collaboration with discussions following the report, we are able to evaluate on our customerscurrent set-up to reduce theirs and our carbon footprint.Commitment to Increased transports In 2025, we expanded our engagement with customers Page 61exploring local running on alternative by more systematically offering bio-based fuel transports decarbonising fuelsas an alternative to fossil-based options and introduced alternatives to fully electric operated trucks among our own fleet.fossil fuelsOwn IRO Upstreamoperation Downstream1Emissions from value chain operations Actual negative impactâ â â2Energy consumption in own operations Actual negative impactâ3Low carbon transports and services Opportunityâ â âESRS 2 SBM-3, E1Material impacts, risks and opportunitiesNTG has identified two impacts and one opportunity to be material in relation to climate change:1 Emissions from value chain operations ImpactNTG arranges low- to medium-carbon transport services delivered by external suppliers on behalfof our customers. As these services rely on conventional fuel technologies, NTGâs business model remains dependent on fossil fuels, which contribute to GHG emissions and global warming.Most of NTGâs emissions arise in the downstreamvalue chain, generated when suppliers perform transport activities on our behalf. As a result, ourclimate impact is primarily indirect and closely linked to the decarbonisation progress of the wider transport sector.Climate change and its consequences are receiving increasing attention across society, and our stakeholders are increasingly calling on NTG to minimise its environmental impact and supportthe transition to lower-carbon transport solutions2Energy consumption in own operationsImpactAlthough most of NTGâs emissions arise within our value chain, we also operate a limited number of own assets, including buildings, company cars, and a small fleet of trucks. These assets generate carbon emissions through their energy use and fuel consumption during day-to-day operations.Energy required to heat, cool, and power our facilities, as well as fuel used in company vehicles and trucks, results in the release of GHG emissions. While comparatively small in scale, these operational emissions still represent a directenvironmental impact and form part of NTGâs overall contribution to climate change. climate.3Demand for zero/low carbon transportsOpportunityShifts towards carbon neutrality may change customer needs, increasing demand for low- or zero-carbon transport solutions. NTG can help meet these expectations by guiding customers through the transition to more sustainable supply chains.Low-carbon fuels and technologies generally carra price premium. Where customers are prepared to invest in these solutions, NTG can support theiclimate ambitions while potentially generating additional revenue from âgreenâ service offerings.This opportunity is already reflected in NTGâs strategy and forms part of our ongoing dialogue with customers on viable options to reduce emissions from our transport and logistics serviceE1 SBM3 Material impacts, risks and opportunities and their interaction with strategy and business modelResilience analysis of NTG's strategy and business modelNTG remains committed to setting emission-reduction targets aligned with the SBTi, aiming to limit global warm-ing to 1.5°C by 2030 and achieve net-zero emissions by 2050, consistent with the Paris Agreement and the latest climate science. In 2026 NTG will align its sustainability strategy with a long-term, Paris-aligned decarbonisation pathway. This work is intended to deepen our understanding of emission sources and inform a robust roadmap for reducing Scopeâ¯1,â¯2, andâ¯3 emissions. Establishing this foundation is central to assessing the climate resilience of our business model and long-term strategy.Limited alternatives for our industryThe transport sector continues to have only a limited number of viable alternatives to fossil fuels. Progress therefore depends on ongoing technological innovation, and the pace of development remains critical.Current low-carbon options face challenges related to scalability, technology readiness, and the availability of supporting infrastructure at local, regional, and global levels. Higher costs also remain a significant barrier, as only a small proportion of stakeholders are currently willing or able to absorb the additional expense. These factors collectively slow the wider adoption of alternative fuels and technologies across the industry.ESRS E1Policies related to climate change mitigation and adaptationNTG's environmental and climate policies address both climate change mitigation and climate change adaptation. Following is a short description the key contents of our policies.E1-2 Code of Conduct for EmployeesEnvironmentWe recognise our responsibility to reduce our environmental footprint and to support low-carbon solutions, including the deployment of renewable energy, as part of broader climate-change mitigation efforts. NTG complies with applicable environmental regulations and seeks to adopt technologies that deliver positive environmental outcomes.To strengthen our climate-adaptation efforts, we are certifying NTG companies under ISOâ¯14001 and encouraging employees to contribute to pollution reduction, resource efficiency, and other environmental protection initiatives.Code of Conduct for SuppliersEnvironment and climateAs an asset-light freight forwarder, NTGâs climate im-pact stems primarily from indirect emissions generated by suppliers. Effective collaboration with both cus-tomers and suppliers is therefore essential to reducing carbon emissions across the value chain. We expect our suppliers to comply with environmental legislation, support NTGâs decarbonisation efforts, and participate in joint environmental initiatives.To strengthen climate-adaptation measures, NTG also encourages suppliers to minimise vehicle idling and to keep drivers informed about fuel-efficient driving practices, helping to reduce unnecessary fuel consumption and associated emissions.ESG and Diversity PolicyEnvironmental impactAs outlined in our ESG and Diversity Policy, NTG aims to enhance transparency regarding our carbon foot-print. We conduct annual carbon-emission estimates in accordance with the Greenhouse Gas Protocol and recognised industry practices, and we continuously assess opportunities to improve carbon efficiency and reduce our overall footprint. Greater transparency supports better decision-making, drives ongoing im-provements, and enables us to offer more sustainable solutions to our customers.NTGâs direct emissions mainly arise from office buildings and terminals, where we have a higher degree of oper-ational control. Although these emissions are limited in scale, we remain committed to identifying and imple-menting viable energy-efficiency measures to further reduce our direct environmental impact across locations.ESRS E1 Actions and resources in relation to climate change policiesE1-3 Actions and resources in relation to climate change policiesStreamlining customer supply chainsNTG prepares a range of customer-specific reports each year to calculate emissions from the transport services purchased. These reports are highly valued, providing transparency on the largest emission sources in customersâ supply chains and helping them identify where reductions can be achieved most effectively. Many customers use the reports to support their own GHG inventories, set reduction targets, and monitor progress over time. Emission reductions resulting from these initiatives have not been quantified. as well as they do not include any significant capital or operational expenditures.Bio-fuel â a decarbonising alternativeNTG continues to explore local alternatives to fossil fuels. In 2025, we expanded our efforts by more systematically offering bio-based fuel options. For a number of years NTGâs Swedish domestic road business has used Hydrotreated Vegetable Oil (HVO), a renewable bio-based fuel. Although more expensive than standard bio-blended diesel, HVO was gradually phased in with key customers accepting an increased surcharge in exchange for reduced emissions. Building on this success, discussions were initiated with subcontractors to adopt HVO and agree on appropriate compensation.In 2025, the cooperation on fuelling HVO continued in more NTG entities with customers and subcontractors and thereby avoided more than 2.600 tonnes of COâe (2024: 2,600) compared with European standard bio-blended diesel. No significant capital or operational expenditures are related to these actions Where NTG has agreed to use biofuels for customer road transports, evidenced biofuel use is reported as supplementary avoided emissions. The calculation compares the GLEC Framework baseline emission factor for standard diesel/biodiesel with the verified biofuel factor, applied to the attributable fuel quantity.Battery electric vehiclesNTG also continues to assess routes where battery electric vehicles (BEVs) are operationally viable. As with HVO, adoption follows a stepwise approach: dialogue with customers, followed by engagement with subcontractors. Because BEVs can cost up to three times more than conventional trucks, investment must be coordinated between all parties. Agreement on charging-infrastructure investments is also essential, given the limited public charging network for heavy-duty vehicles in Northern Europe.In 2025 several BEVs where in daily operation in our linehaul traffics and introduction of more BEVâs are scheduled. Details on the operational expenditure impact can be found in the Taxonomy section on p. 71.These bio-fuel and BEV initiatives have the potential to reduce NTGâs direct Scopeâ¯1 emissions or indirect Scopeâ¯3 emissions, depending on whether the assets are operated by NTG or by external suppliers.ESRS E1Targets related to climate change mitigation and adaptationE1-4 Targets related to climate change mitigation and adaptationNTG is advancing its work on managing material climate impacts by preparing concrete targets to reduce our environmental footprint. We plan to introduce two global GHG-reduction targets: an absolute reduction for our combined Scopeâ¯1 and Scopeâ¯2 emissions from owned activities, and an intensityâbased reduction target for Scopeâ¯3 emissions across our upstream and downstream value chain.In 2026 NTG will align its sustainability strategy with a long-term, Paris-aligned decarbonisation pathway resulting in NTG being able to present its reduction targets to SBTi during the year.To achieve the future targets, NTG has identified two principal strategic pathways. Reducing Scopeâ¯1 and 2 emissions will require a transition to renewable energy across our own operations. Reducing Scopeâ¯3 emissions will depend on close collaboration with customers and suppliers to lower emissions from transport activities within our value chain.ESRS E1Gross Scopes 1, 2, 3 and Total GHG emissionsNTGâs total GHG emissions increased in 2025 primarily reflecting our expanded operational activity and the consolidation effects of recent acquisitions and full-year consolidation of acquisitions completed at the end of 2024.E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions Scope 1 GHG emissions NTGâs direct (Scopeâ¯1) emissions arise from fuel consumed in owned and controlled vehicles as well as energy used in our buildings. The acquisitions complet-ed during 2025 expanded NTGâs operational asset base, contributing to a marked increase in direct emissions. Gross Scopeâ¯1 emissions almost doubled compared with 2024, primarily driven by a higher number of NTG operated trucks and vans.NTGâs company car policy, introduced in 2022, restricts purchases to electric or plug in hybrid vehicles. While re-cent acquisitions added a limited number of fossil fuelled cars to the fleet, the overall share of electric and plug in hybrid models continued to rise and now represents more than half of all company cars.Scope 2 GHG emissionsScopeâ¯2 emissions from purchased electricity, district heating, and steam also increased in 2025. This devel-opment reflects higher energy consumption in buildings as well as growing electricity demand for charging the expanding fleet of electric company cars.Renewable energy from rooftop solarSeveral NTG entities continued to produce zero emission electricity from rooftop solar installations. Installed capacity increased again during 2025, resulting in higher renewable output from these systems.The country level overview highlights Germany, Denmark, and Sweden as the largest contributors to Scopeâ¯1 and 2 emissions, reflecting the relative scale of NTGâs opera-tions and asset footprint in these markets.Scope 3 GHG emissions - overviewScopeâ¯3 emissions continue to dominate NTGâs carbon footprint, accounting for approximately 98% in 2025. The main contributor is Category 4 â Upstream Transpor-tation and Distribution, that contains all subcontracted road, air, ocean and rail transport paid for by NTG.Although low carbon alternatives remain more costly than fossil fuel options, customer collaboration and subcontrac-tor engagement continued to strengthen. In 2025, NTGâs subcontractors increased their consumption of sustainable biofuels, avoiding more than 2,600 tonnes of COâe, com-pared with the use of European standard bio blended diesel.% ESRS IDs Unit 2025 2024*(2024/2025)Gross Scope 1 GHG emissions and total GHG emissionsE1-6_01, Gross Scope 1 GHG emissions and total GHG emissions 15,486 7,765 99.4%E1-6_02, E1-6 Buildings tonnes COe 1,839 1,217 51.1%2-04, E1-6-05, Company cars tonnes COe 1,582 1,188 33.2%2E1-6_06, E1-6-07, E1-6_27Own/leased trucks and forklifts tonnes CO2e 12,065 5,360 125.1%Gross Scope 2 GHG emissions and total GHG emissions (Location-based) 2,266 1,451 56.2%Buildings tonnes COe 2,182 1,389 57.1%2Company cars tonnes COe 76 60 27.2%2Electric trucks tonnes COe 8 2 257.8%2Gross Scope 2 GHG emissions and total GHG emissions (Market-based) 5,448 3,241 68.1%Buildings tonnes COe 5,230 3,093 69.1%2Company cars tonnes COe 201 144 39.6%2Electric trucks tonnes COe 17 4 325.0%2Gross Scope 3 GHG emissions 996,899 822,348 21.2%Category 4 - Upstream Transportation and Distribution tonnes COe 932,631 775,786 20.2%2Road transport tonnes COe550,193438,696 25.4%2Railway transport tonnes COe453228 98.7%2Air Transport tonnes COe257,493215,335 19.6%2Ocean transport tonnes COe124,492121,527 2.4%2Category 1 - Purchased goods and services tonnes COe 11,781 7,754 51.9%2Category 2 - Capital goods tonnes COe 4,435 2,471 79.5%2Category 3 - Fuel and energy-related activities tonnes COe 5,425 2,509 116.1%2Category 5 - Waste generated in operations tonnes COe 782 691 13.2%2Category 6 - Business travel tonnes COe 39,913 31,427 27.0%2Category 7 â Employee commuting tonnes COe 1,932 1,709 13.0%2Total GHG emissionsTotal COe GHG emissions - scope 1, 2 and 3 (location-based) tonnes COe 1,013,902 831,564 22.0%22Total COe GHG emissions - scope 1, 2 and 3 (market-based) tonnes COe 1,017,084 833,354 22.1%22ESRS ID Biogenic emissions Unit 2025 2024*GHG emissions outside of scopesE1-6_28 Biogenic emissions of CO from combustion or 2bio-degradation of biomass that occur in value chain not included in Scope 3 GHG emissions tonnes COe 2,763 2,7222GHG emissions revenue intensityE1-6_30GHG Emission revenue intensity tonnes E1-6_31- Location-basedCOe/DKKm 89.1 88.92GHG Emission revenue intensity - Market-based tonnes COe/DKKm 89.4 89.12ESRS ID Country Unit 2025 2024Scope 1 and Scope 2 GHG emissions - Countries with highest emissionsE1-6_03Germany, Scope 1 tonnes COe 9,355 3,3052Denmark, Scope 1 tonnes COe 4,054 2,2762Sweden, Scope 1 tonnes COe 1,002 1,0062Other, Scope 1 tonnes COe 1,074 1,1782Total, Scope 1 tonnes COe 15,486 7,7652Germany, Scope 2 tonnes COe 1,142 3572Denmark, Scope 2 tonnes COe 292 2652Sweden, Scope 2 tonnes COe 126 1252Other, Scope 2 tonnes COe 706 7042Total, Scope 2tonnes COe2,266 1,4512* Refer to the next page for more information.E1-6Accounting policies, methodologies and significant assumptionsAccounting policy*NTG has revised its accounting and calcula-tion methodology to include GHG emissions from additional relevant market-based Scope 2 and Scope 3 categories, thereby enhancing transparency regarding its climate-related im-pacts. As a result, NTGâs 2024 GHG emissions have been restated in datapoints E1-6_10 , E1-6_11 and E1-6_13. Consequently, the 2024 data reported in E1-6_13 are restated as Well-to-Wheel GHG emissions and E1-6_30, E1-6_31 restated as total GHG emissions rev-enue intensity. For more information se BP-2.Key accounting estimations and assumptions, Scope 1, 2 and 3 GHG emissionsThere are inherent sources of estimation and uncertainty in GHG emissions. These uncertainties stem from the methodologies and assumptions employed in calculations. To minimise these uncertainties and maintain transparency, NTG follows established standards and protocols.Scope 1 and 2 GHG emissions are calculated using actual data where available, combined with emission factors for relevant activities. Estimates have been applied when actual data on consumption was not available. Estimates have been based on factors applied from similar activities in NTG in accordance with internal NTG reporting guidelines.Scope 3 GHG emissions are calculated using actual transport data from own transport management systems where available covering 98% of our transport activities. The remaining emissions are estimated based on extrapolation of information on revenue from transport activities to reach full coverage of our transport activities.E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions NTG's carbon footprint provides a general overview of the company's greenhouse gas emissions converted into CO equivalents 2(COe). The emissions reported in scope 1, 22 and 3 are based on the definitions in the Green House Gas Protocol (âGHG Protocolâ). The reported total scope 1, 2 and 3 emissions consolidate the emissions data of all companies in the structure of NTG, all of them being under the full financial and operational control of NTG, and each one of them being a part of the consolidated accounting group. NTG does not have any additional entities, activities or projects under its operational control (i.e. "investees such as associates, joint ventures, or unconsolidated subsidiaries that are not fully consolidated in the financial statements of the consolidated accounting group, as well as contractual arrangements that are joint arrangements not structured through an entity").Gross scope 1 GHG emissions (E1-6_07)Direct carbon dioxide equivalent (COe) 2emissions based on reported or estimated consumption from owned or controlled sources, which are company cars and forklifts powered by fossil fuels, our own small fleet of trucks, forklifts used in our terminals and warehouses (fuelled with diesel or propane gas) and consumption of natural gas or heating oil in own buildings. Emissions from buildings are calculated using emission factors from UK Government GHG Conversion Factors for Company Reporting (DEFRA), Version 1, 2025. Emissions from company cars, forklifts and owned trucks are calculated using emission factors per relevant fuel type from DEFRA and GLEC Framework for logistics emissions, accounting and reporting, version 3.2 (GLEC).Gross location-based Scope 2 GHG emissions (E1-6_09)Scope 2 GHG emissions are calculated and disclosed by applying the location-based approach following the GHG protocol. The basis for calculationg the Scope 2 GHG emissions is NTG entities' reported or estimated (in some specific cases) consumption from purchased electricity and district heating in own buildings; and from purchased and consumed electricity in own company cars and electric trucks. The frameworks used as a source basis of emission factors for calculating carbon emissions are www.ourworldindata.org for the electricity emission factors for the energy used both in buildings and vehicles, and DEFRA regarding district heating consumption in own buildings.Gross market-based Scope 2 GHG emissions (E1-6_10)Market-based Scope 2 GHG emissions are calculated based on the energy consumption from purchased electricity in all NTGâs building locations, company cars and electric trucks. Emission factors used follow the hierarchy outlined in GHG protocol â Scope 2 Guidance: where available, emission factors from renewable energy certificates and supplier-specific emission factors are applied, and, where such instruments are unavailable â the source frameworks of emission factors of AIB, Green-e, EPA and www.ourworldindata.org are applied. Gross Scope 3 greenhouse gas emissions (E1-6_11), Gross Scopes 1, 2, 3 and Total GHG emissions - Scope 3 GHG emissions (GHG Protocol) (E1-6_04), Gross Scopes 1, 2, 3 and Total GHG emissions - Scope 3 GHG emissions (ISO 14064-1) (E1-6_05), Gross Scopes 1, 2, 3 and Total GHG emissions - total GHG emissions - value chain (E1-6_06), List of Scope 3 GHG emissions categories included in inventory (E1-6_27), Reporting of indirect Scope 3 GHG emissions follows the GHG Protocol, which classifies Scope 3 emissions into 15 categories. Based on NTGâs materiality assessment and screening, the following Scope 3 categories are considered relevant: Category 1 (purchased goods and services), 2 (capital goods), 3 (fuels and energy-related activities), 4 (upstream transportation and distribution), 5 (waste generated in operations), 6 (business travel) and 7 (employee commuting).GHG emission calculations for categories including Category 1 (purchased goods and services), 2 (capital goods), 5 (waste generated in operations) and 6 (business travel) are performed using GHG Protocol endorsed method of using spend-based data. GHG emission factors from Climatiq (www.climatiq.io) have been applied in the calculations. GHG emission calculations for category 3 (fuels and energy-related activities) result from both fuels (Scope 1) and purchased electricity, steam, heating and cooling (Scope 2) by NTG. The emission factors from DEFRA, GLEC and the International Energy Agency (IEA) database of Life cycle Upstream emission factors 2025 have been applied in the calculations. Accounting policyGHG emission calculations for category 7 (Employee commuting) were estimated using the average-data method, total number of full-time employees from NTG, national statistics on commuting patterns and emission factors from DEFRA have been applied in the calculations.Most of NTG's scope 3 GHG emissions are from transportation and distribution services as the main part of the services/capacities are purchased from hauliers, ocean carriers, airlines, and other capacity providers and more than 92% of the total carbon emissions originates from our subcontracted activities. NTG Group's revenue generating activities are the basis for data for calculating category 4 (Upstream transportation and distribution) emissions eliminated for irrelevant, non-transport revenue generating activities. Indirect CO emissions from transport 2activities are aligned with methodolgies in the GLEC Framework. Carbon dioxide equivalent emissions are disclosed following the Well-To- Wheel (WTW) approach for our transport activities except where otherwise stated.Category 4 emissions are calculated based on transport data from NTG standard transport management systems (90%) and from legacy transport management systems (10%), including data on freight volumes transported by different transport modes to and from different destinations. As data from our standard transport management systems is considered to contain greater transparency, and NTG plans to transfer activities from legacy transport management systems to standard transport management systems.Transport data from our standard and legacy transport management systems cover 97% of scope 3 GHG emissions from our transport activities. The remaining emissions are estimated based on extrapolation of information on revenue from transport activities and average emission factors to reach full coverage of emission from our activities.For road transports NTG estimate emissions partly on the average fuel utilisation ratios reported for trucks owned by NTG and by subcontractors and used for the transports of NTG's customers freight, and partly on transport data from NTG's traffic management systems. For railway transports NTG estimates emissions partly on the average emissions from the EcoTransIT World calculator using data from main fossil fuelled traffic lines for the transports of NTG's customers freight, and partly on transport data from NTG's traffic management systems. The data base for railway carbon emission calculations is subject to uncertainty and is not complete. Incomplete data for railway transport is included conservatively among NTG's other modes of transport. We will continue our work on improving the insufficient data base.For ocean transports NTG estimates emissions partly on the Clean Cargo Working Group, which collects information on global container shipping trade lane emissions factors from subcontractors used by NTG for the transports of NTG's customers freight, emission factors from GLEC and partly on transport data from NTG's traffic management systems.For air transports NTG estimates emissions partly on the average carbon emissions reported by subcontractors and used for the transports of NTG's customers freight, and partly on transport data from NTG's traffic management systems.GHG emissions - by country, operating segments, economic activity, subsidiary, GHG category or source type (E1-6_03)The table presents the distribution of Scope 1 and 2 GHG emissions by country, showing the three countries with highest emissions from NTG's own assets.Biogenic emissions of CO from combustion 2or bio-degradation of biomass that occur in value chain not included in Scope 3 GHG emissions (E1-6_28)The metric presents Scope 3 biogenic emission from combustion of biofuel (HVO100) calculated as a WTW emission. This biogenic emission is considered out of the other emission scopes and is calculated based on the consumption of HVO100 fuel purchased by subcontractors and used to perform transports by NTG entities. Emission factors is from GLEC.GHG emissions revenue intensity (total GHG emissions per net revenue) (E1-6_30, E1-6_31)GHG revenue intensity (COe (tonnes/2DKKm)) Total GHG emissions (scope 1, 2 and 3), both market-based (Total GHG emissions - market-based) and location-based (Total GHG emissions â location-based), divided by total net revenue. Total net revenue is reconciled to financial statements on page 18, Condensed income statement.Percentage of Scope 1 GHG emissions from regulated emission trading schemes (E1-6_08)NTG doesn't participate in regulated emission trading schemes.Biogenic emissions of CO from combustion 2or bio-degradation of biomass not included in Scope 2 GHG emissions (E1-6_24)NTG has no Scope 2 related biogenic emissions of CO from the combustion or bio-2degradation of biomass.Disclosure of reconciliation to financial statements of net revenue used for calculation of GHG emissions intensity (E1-6_32)The net revenue has been reconciled to the Annual report, page 18, Condensed income statement.Net revenue (E1-6_33), Net revenue used to calculate GHG intensity (E1-6_34)The net revenue has been reconciled to the Annual report, page 18, Condensed income statement.Net revenue other than used to calculate GHG intensity (E1-6_35)NTG has no revenue from any other activities.ESRS E1Energy consumption and mixE1-5 Energy consumption and mix The energy consumption and mix in NTGâs own operations and controlled entities is presented in the tables on this page. NTGâs energy consumption relates to NTGâs own operations, representing energy from fossil sources (oil and petroleum products and natural gas) from fuels, electricity, and district heating.Renewable sources include energy produced and consumed from roof-top mounted solar panels installed on NTG buildings and renewable energy from renewable energy certificates.ESRS ID Metric Unit 2025 2024Energy consumptionE1-5_01, Total energy consumption MWh 177,759 150,055E1-5_19E1-5_02 Energy consumption from fossil sources MWh 62,799 31,532E1-5_11 Fuel consumption from crude oil and petroleum products MWh 53,464 25,933E1-5_12 Fuel consumption from natural gas MWh 9,335 5,600E1-5_14 Consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources MWh 114,960 118,522E1-5_06 Fuel consumption from renewable sources MWh 10,830 10,671Energy intensity and mixE1-5_18 Energy intensity per net revenue MWh/DKKm 15.62 16.02E1-5_09 Percentage of renewable sources in total energy consumption % 0.45 0.42E1-5_15 Percentage of fossil sources in total energy consumption % 99.55 99.58Renewable energy: production and consumptionE1-5_05, Total energy consumption from renewable sources, Consumption of self-generated non-fuel renewable energy MWh 808.09 635.58E1-5_08 E1-5_17 Renewable Energy: Total Production MWh 1.101,60 880.05E1-5Accounting policies, methodologies and significant assumptionsAccounting policyAll reported energy metrics refer to NTG's own operations and controlled entities, as-sets and vehicles. All metrics derives from in-formation collected from all NTG entities per asset type and relevant consumption based on presented consumption documentation. To ensure completeness in the reported data, estimations were used in some specific cases where the data from actual consumption was inaccessible. Estimations are based on the average consumption for the respective asset and type of consumption from other NTG entities.Any measurements of metrics related to energy consumptions disclosed have not been validated other than by the assurance provider.Total energy consumption (E1-5_01) and Total energy consumption from activities in high climate impact sectors (E1-5_19) The reported amount of total energy con-sumption includes the energy consumption from fossil sources (crude oil and petroleum products, and natural gas fuels) and the Con-sumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources. The same amount has been reported under datapoint E1-5_19 (Total energy consumption from activities in high climate impact sectors) due to the assumption that all all NTG ac-tivities are in high climate impact sector - all own activities of the company are supporting transportation. Transportation activities fall within NACE code, section H - Transporting and storage as defined in the Regulation (EU) 2019/2088 and Annex 1 of the related Del-egated Regulation with regard to disclosure rules on sustainable investments. Energy consumption from fossil sources (E1-5_02), from crude oil and petroleum products (E1-5_11) and from natural gas consumption (E1-5_12)The reported amount of energy consumption from fossil sources includes the crude oil and petroleum products used for heating of owned and leased building premises; and the fossil fuels used for owned and leased cars and trucks - gasoline (cars) and diesel (cars, trucks, forklifts fueled by diesel), and natural gas fuels used for heating of owned and leased building premises and the gas propane used for fueling of owned and leased forklifts. Consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources (datapoint E1-5_14)Includes the total electricity consumption from owned and leased buildings, cars, and electric trucks, and the district heating for buildings. Further, these components of the consumption are used as the basis for calcu-lating Scope 2 GHG emissions. Total energy consumption from re-newable sources (E1-5_06)Total energy consumed from renewable sources at NTG's locations, including renew-able certificates and production from own solar panels.Energy intensity from activities in high climate impact sectors - total energy consumption per net revenue (E1-5_18)The metric is calculated as a total energy consumption in high climate impacts sectors per unit of net revenue net revenue (DKKm), so the result is presented as MWh/DKKm.Percentage of renewable sources in total energy consumption (E1-5_09)The metric presents the consumed self-gen-erated renewable energy produced by NTG entities roof-top mounted solar panels, reported in datapoints E1-5_05 and E1-5_08), as a share of the total energy consumption (reported in datapoint E1-5_01). Percentage of fossil sources in total energy consumption (E1-5_15)The metric is based on the assumption that all NTG's energy consumption from own ac-tivities comes from fossil sources except the energy produced from the own solar panels.Total energy consumption from renewable sources (E1-5_05), Consumption of self-generated non-fuel renewable energy (datapoint E1-5_08) Energy generated and consumed through any method under NTGâs direct operational control, whether used in NTGâs own operations or supplied to third parties, is included. At present, NTGâs energy production consists solely of electricity generated from solar panels and renewable energy from renewable energy certificates.Total renewable energy production from renewable sources (E1-5_17)Energy generated through any method under NTGâs direct operational control, whether used in NTGâs own operations or supplied to third parties, is included. At present, NTGâs energy production consists solely of electrici-ty generated from solar panels.Total energy consumption from nuclear sources (E1-5_03), Percentage of energy consumption from nuclear sources in total energy consumption (E1-5_04)NTG don't have available information which could distinguish any direct energy consump-tion from nuclear sources.Fuel consumption from coal and coal products (E1-5_10), Fuel consumption from other fossil sources (E1-5_13)NTG does not consume fuel from other fossil sources than already disclosed.Fuel consumption from renewable sources (E1-5_06), Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (E1-5_07)Energy generated through any method under NTGâs direct operational control, whether used in NTGâs own operations or supplied to third parties. At present, NTGâs energy production consists solely of electricity generated from solar panels and renewable energy from renewable energy certificates.High climate impact sectors used to determine energy intensity (E1-5_20)All NTG energy consumption is considered related to high climate impact sector because all own activities of the company are support-ing transportation. Transportation activities fall within NACE code, section H - Transport-ing and storage as defined in the Regulation (EU) 2019/2088 and Annex 1 of the related Delegated Regulation with regard to disclo-sure rules on sustainable investments.Net revenue from activities in high climate impact sectors (E1-5_22)NTG don't have revenue from activities other than in high climate impact sector - transpor-tation. The net revenue is used for the metric as it is disclosed in financial statements on page 18, Condensed income statement.E1-7 GHG removals and GHG mitigation projects financed through carbon creditsNTG has not financed any GHG removals or GHG mitigation projects through carbon credits.E1-8 Internal carbon pricing NTG does not apply internal carbon pricing schemes in its business.Total GHG emission 1,014,651 tCOe2Scope 115,486 tCOe 2Direct emissions based on the Greenhouse Gas Protocol, from our own activitiesScope 22,266 tCOe 2Indirect emissions based on the Greenhouse Gas Protocol, including emissions from generation of electricity, and heatScope 3996,899 tCOe2Indirect emissions from our value chain, based on the Greenhouse Gas Protocol, including emissions from freigh forwarding servicesESRS E2PollutionNTG's transport activities are delivered through our international network, encompassing road, rail, air, and ocean freight arranged on behalf of our customers. All these transport modes are predominantly powered by fossil fuels, which contribute significantly to air pollution. NTG has assessed this to be a material pollution-related impact within our upstream value chain.To evaluate these impacts, NTG applied the same methodology used in IROâ1 (pageâ¯54) for identifying and assessing material impacts, risks, and opportunities. This approach covers pollution-related effects arising from our own operations as well as from activities across both our upstream and downstream value chains.ESRS 2NTG's impacts, risks and opportunitiesNTG efforts to reduce GHG emissions will have a dual benefit for air quality and climateIRO-1, E2 Description of the processes to identify and assess material pollution-related impacts, risks and opportunitiesWhen fossil fuels are burned for transport, they re-lease particulate matter, sulphur dioxide (SOâ), nitro-gen oxides (NOâ), volatile organic compounds (VOCs), and greenhouse gases such as COâ, CHâ, and NâO.The World Health Organisation (WHO) highlights that air pollution and climate change share the same root causes, noting that policies to reduce air pollu-tion create simultaneous health and climate benefits.Aligned with this perspective, NTG recognises that reduced fuel combustion lowers both GHG emissions and air pollutants across the value chain. We therefore expect that any reduction in GHG emissions from our activities will directly decrease pollution from fossil-fuel combustion.Customersâ focus is solely on GHG emissionsNTG maintains regular dialogue with customers on the environmental impact of transport services. Annual customer-specific emissions reports consistently focus on GHG data, with limited interest in air pollutantsâlikely reflecting long-standing air-quality regulations in many of the countries where our customers operate.As climate awareness grows, customer priorities have shifted towards reducing GHG emissions. NTG aligns with these expectations and concentrates its efforts accordingly. Because fossil-fuel-related pollution and GHG emissions share the same source, prioritising GHG reductions remains both practical and responsive to customer needs.E2-1, E2-2, E2-3, E2-4 4NTG's position on the impact on air pollutionAir pollution related impacts, risks, and opportunities form part of the broader environmental protection topic and are therefore relevant to understanding NTGâs overall environmental and climate footprint. NTG acknowledges in its Employee Code of Conduct that minimising such impacts is a material responsibility.Under ESRS requirements, disclosures on air pollution apply to own operations and facilities under operational or financial control. As an asset-light business, NTGâs pollution related impacts occur almost entirely within the upstream value chain, where we do not exercise direct control. Consequently, NTG does not currently have full access to relevant data on its air pollution. We will work to improve our access to such data.NTG continues its focus on the GHG reduction measures outlined in ESRS E1 on climate change. These initiatives directly reduce fuel consumption in transport activities and, in turn, lower associated air pollutant emissions.NTG will continue to work closely with customers and suppliers to reduce transport related GHG emissions across the value chain. We will also communicate more clearly about the relationship between GHG reductions and decreases in air pollution to support broader understanding of how value chain decarbonisation contributes to environmental protection.Social informationESRS S1Own workforceNTG operates globally through a decentralised structure and locally anchored expertise across multiple countries. This model enables us to manage shipments of any size, destination, or complexity while leveraging advanced technology platforms to deliver efficient, reliable, and cost-effective logistics solutions tailored to our customersâ needs.However, technology alone cannot achieve our sustainability ambitions. Our success depends on passionate and committed employees who em-brace NTGâs vision and values. Every day, they engage with customers and suppliers, implement strategies, and recognise the wider impact of their work - on our customers, our company, and the communities where we operate.Our people strive for excellence and aim to cre-ate positive outcomes for all stakeholders. As a service-driven organisation, NTG relies on the skills and expertise of its workforce to meet our goals and advance our ESG commitments. Each employee plays a vital role in delivering NTGâs vision of being the preferred choice for trans-port solutions while contributing to responsible and sustainable business practices.We influence the employee experience through our culture, benefits, policies, and practices, en-suring NTG remains a workplace where talent thrives in everyday operations.ESRS 2 S1KPIs 2025 Progression Read moreReduce rate of recordable 9.6 Despite our efforts, we do record incidents each year where Page 85work-related accidents for employees sustain injuries. To mitigate these occurrences, own workforce, per million we document and analyse every incident to determine the working hours every yearcause.We will have no fatalities 0 fatalities NTG has been measuring, monitoring, and reviewing our Page 85among our employeeshealth and safety protocols and acted on any escalations. This has meant another year without any fatalities. We aim to keep it that way.Top management targets 18.2% NTG has successfully met its target of reaching at least 10%Page 82to reach a representation representation of the underrepresented gender, wellof 10% of the underrepre-ahead of the 2027 deadline. We are proud of thissented gender in 2027 at progress and have now raised our ambition.the latest.Own IRO Upstreamoperation Downstream5Health and safety Actual negative Impactâ6Diversity Riskâ7Privacy Actual negative ImpactâSBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelNTG has identified two negative impacts and a risk that are being assessed as material to NTG within the topic own workforce. These areas are closely linked to our strategic priorities and influence how we manage our business model responsibly.5Health and SafetyNegative impact Health and safety are a material impact for NTG, particularly concerning warehouse employees and NTG-employed truck drivers. These roles involve inherent risks of workplace injuries and other health-related issues, which could have severe consequences, including fatalities. Ensuring a safe working environment is therefore a critical priority for NTG, embedded in our operational standards and continuous improvement initiatives.6PrivacyNegative impact Operating in the transport and logistics sector involves processing large volumes of data daily. All NTG employees are subject to privacy impacts due to data collection from sources such as transport management systems, payroll administration, employment records, and video surveillance.While some data is essential for operational purposes such as managing customer arrangements and transport supervision, NTG recognises its responsibility to protect personal information from unauthorised access or misuse. We comply with applicable data protection regulations and uphold the privacy and rights of individuals, including employees, applicants, visitors, customers, business partners, and third parties.7DiversityRisk NTG acknowledges the importance of gender diversity and the associated material risks. As a Danish-based publicly listed company, we face increasing regulatory and stakeholder expectations regarding gender composition, particularly within the Board of Directors and top management.The transport industry traditionally has a lower representation of women, particularly in operational and commercial roles. In support functions such as HR and finance, the challenge is typically less industry specific. NTG is committed to addressing this challenge and we recognise that achieving these targets is essential for maintaining our reputation and ensuring regulatory compliance, and we are actively advancing initiatives to build a more inclusive and diverse workplace.No Positive Material ImpactsNTG has not identified any positive materialimpacts within its workforce.MDR P, S1-1 Policies related to own workforceNTGâs Employee Code of Conduct and ESG & Diversity Policy define how we work responsibly and guide our business practices. These policies set standards for working conditions, employment practices, occupational health and safety (including the prevention of work-related injuries), and human rights (including the prohibition of forced, exploitative, and child labour).The purpose of the Employee Code of Conduct is to provide clear guidance on acting in a legally and ethically correct manner in various situations. It applies to all NTG Group entities and employees, outlining principles for performing their roles, particularly when ethical or legal boundaries may be challenged. The Code ensures that employees take personal responsibility and uphold the ethical expectations described, thereby safeguarding NTGâs reputation and integrity.Both the Code of Conduct and the ESG & Diversity Policy apply across the Group and establish principles for responsible behaviour. NTG supports understanding and compliance through regular training sessions, ensuring employees are equipped to follow these guidelines.Accountability for these policies rests with the Board of Directors, while Executive Management oversees their day-to-day implementation. Local managing directors are responsible for applying these policies within their entities and guiding employees to make sound decisions in line with the Code of Conduct and ESG & Diversity Policy.MDR A, S1-4 Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actionsWork-related injuries preventionAEmployee safety is NTGâs highest priority. We monitor key indicators on workplace accidents and related absence to ensure continuous improvement within the material impact concerned.Our operations involve long-distance transport in dense traffic, heavy machinery, and complex coordination, which carry inherent risks. While the transport industry can experience severe or even fatal incidents, NTG has never recorded a fatality, and we are committed to maintaining this record.Despite preventive measures, injuries do occur. All incidents are documented, analysed, and reviewed locally to identify root causes and update procedures where necessary. We set annual targets to reduce both the frequency of work-related injuries and absence days, recognising that accident severity often correlates with time away from work.Diversity in NTGNTG is committed to fostering a diverse workforce and leadership team across age, nationality, gender, and background. We view diversity as a driver of innovation and better decision-making, enabling us to deliver creative solutions and meet the needs of a global customer base. Our international operations bring together varied perspectives, strengthening collaboration and problem-solving.Our ESG & Diversity Policy underpins this commit-ment, ensuring fair and objective treatment of all em-ployees and applicants, with zero tolerance for discrim-ination. We aim to attract and retain talent through equal opportunities for growth and development.Looking ahead, NTG will implement a more focused strategy with relevant actions to further improve diversity across the organisation.Data privacy Data is a key asset in NTGâs transport and logistics operations, collected from sources such as vehicle tracking and video surveillance to optimise services and meet customer needs. With this comes responsibility.We are committed to protecting personal data and respecting individual rights. NTG complies with relevant data protection laws, including the EU General Data Pro-tection Regulation (GDPR), and applies strict safeguards through our IT and security systems. Our data protec-tion framework ensures that personal data is collected, stored, used, and shared only for legitimate purposes, and deleted or anonymised when no longer required.To support compliance, we use dedicated data privacy software and provide regular employee training on secure and respectful data handling. MDR-T, S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesNNTG sets and monitors targets for health and safety and diversity, taking corrective action when progress deviates from expectations.Health and safetyWe aim to reduce both the rate of work-related incidents and the number of absence days caused by accidents each year. In 2025, the work-related accident rate was 9.6 per million working hours, compared with 5.2 in 2024. The increase primarily reflects stronger awareness of reporting requirements and NTGâs ex-pansion within road and warehouse operations, which traditionally have higher injury rates. NTG will continue to closely monitor the development of work-related ac-cidents as the newly integrated business areas mature.We also maintain a zero-fatality target with no expiry date. NTG has never recorded a fatality, and we are committed to preserving this record.DiversityDiversity is a strength for NTG, and we focus on improving gender balance. Our ESG & Diversity Policy commits us to fair treatment and equal opportunities for all employees and applicants, and have no tolerance for discrimination.We have set a new target for at least 30% represen-tation of the underrepresented gender in Executive Management and direct reports by the end of 2028 at the latest. This is a consequence of the previous target having already been achieved in 2025. Progress is re-viewed annually at Group level. The Board of Directors aims to ensure that at least 40% of its members are from the underrepresented gender by 30 June 2026.Data privacyOur data protection approach is based on recognised cybersecurity frameworks such as ISO 27001 and CIS Controls. We use compliance tools to map personal data flows and strengthen transparency and accountability. Employees receive training on responsible data handling.While NTG has not yet set measurable targets for data privacy, we plan to develop relevant goals to improve impact management. We will also continue to build knowledge on data ethics and AI, collaborating with stakeholders to implement best practices.S1-2 Processes for engaging with own workforce and workers' representatives about impactsNTGâs global operations are supported by a decentralised organisational structure and locally anchored expertise across multiple countries. This approach enables us to manage shipments of any size, destination, or complexity while leveraging advanced technology platforms to deliver efficient, reliable, and cost-effective logistics solutions tailored to customer needs. However, technology alone cannot achieve our goals. Our success depends on passionate and committed employees who share and understand NTGâs vision and values.Employees are the driving force behind NTG. They interact daily with customers and suppliers, implementing strategies and plans while recognising the impact of their work on our customers, the company, and the communities in which we operate. Our people strive for excellence and aim to create positive outcomes for all stakeholders. Their skills and qualifications are essential to achieving NTGâs objectives, and every employee plays a vital role in fulfilling our vision of being the preferred choice for transport solutions.Responsibility for communicating NTGâs position on these matters lies with Executive Management, through the ESG & Diversity Policy and the Employee Code of Conduct. While NTG does not have a Global Framework Agreement, our company values guide employees in respecting freedom of association, promoting equal opportunities and diversity, and prioritising a safe and healthy work environment.These principles form the foundation for daily dialogue between employees and management in addressing operational challenges. To strength-en engagement, NTG conducts annual employee satisfaction surveys among ISO-certified companies, supplemented by internal surveys. These cover topics such as health and safety, diversity, and privacy, providing management with insights into employee perspectives. Survey results are shared openly and discussed with employees to identify improvements, and NTG aims to achieve satisfaction scores above industry benchmarks.In addition, NTG collects data on workplace accidents and diversity metrics, which inform actions to drive continuous improvement. Health and safety engagement is managed locally through appointed representatives at various sites and through investigations of incidents, ensuring lessons are learned and preventive measures implemented.S1-3 Processes to remediate negative impacts and channels for own workforce to raise concernNTG promotes a strong culture of responsibility and provides clear channels for employees to report concerns. Breaches of law, the Code of Conduct, or issues such as health and safety or data privacy can be reported to managers, NTG Group Legal, or via our Whistleblower System, managed by an independent third party to ensure anonymity. Employees reporting in good faith are protected against retaliation, and all cases are handled confidentially.Awareness is reinforced through onboarding and regular training. NTG complies with all applicable laws and will remediate and compensate employees if material negative impacts occur.ESRS 2 S1-6S1-6 Characteristics of the workforceNTG year NTGâs workforce continued to grow and transform in 2025, driven by organic activity and the full-year effect of acquisitions completed in the period. NTGâs workforce in 2025 reflects a growing, international organisation with operations across more than 30 entities in Europe, Asia, and the Americas. Workforce sizes vary from small administrative units to large operational entities particularly in operational clusters in main countries as Germany, Denmark, Sweden, and the US.Despite the growing workforce some other characteristics remained stable such as the age distribution, with steady representation of younger and older age groups across regions. An overall stable gender distribution, with male dominated operational roles continuing to influence the Group-wide average. NTG continues to see higher female representation in administrative and forwarding roles than in labour-intensive logistics functions. Finally, age and seniority distributions show continuity, with the largest share of employees having 1â10 years of tenure in NTG.S1-6 Characteristics of NTG's employeesESRS ID 2025 2024*S1-6 Number of employees (FTE)Number of employees (FTE) 3,211 2,723Entity specific Salaried employees (FTE) 2,106 1,879Entity specific Hourly workers (FTE) 1,105 844S1-6 Number of employees and gender (head count)**Number of employees (headcount), total 3,481 2,932Number of employees (headcount), female 1,100Number of employees (headcount), male 2,381Number of employees (headcount), other 0 0Number of employees (headcount), not reported 0 0Proportion of female employees (headcount) - % 31.6Proportion of male employees (headcount) - % 68.4Proportion of other employees (%) 0 0Proportion of not reported employees (%) 0 0Country distribution and distribution by gender in countries with 50 or S1-6more employees representing at least 10% of total number of employeesCountry distribution: Denmark (Headcount), number of employees 947 726Female employees in Denmark (Headcount), number 199Male employees in Denmark (Headcount), number 748Country distribution: Germany (Headcount), number of employees 1,078 866Female employees in Germany (Headcount), number 319Male employees in Germany (Headcount), number 759Country distribution: Sweden (Headcount), number of employees 393 331Female employees in Sweden (Headcount), number 88Male employees in Sweden (Headcount), number 305ESRS ID 2025 2024*S1-6 Employees per contract type and gender (Headcount)**Employees hired on a full-time contract (Number) 3,047Proportion of employees hired on a full-time contract (All) - % 87.5*Proportion of employees hired on a full-time contract - Female - % 29.1*Proportion of employees hired on a full-time contract - Male - % 70.1Employees hired on a part-time contract (Number) 434Proportion of employees hired on a part-time contract (All) - % 12.5*Proportion of employees hired on a part-time contract - Female - % 48.8*Proportion of employees hired on a part-time contract - Male - % 51.6S1-6 Permanent and temporary employeesPermanent employees, number (Headcount) 3,481 2,932Temporary employees, number (Headcount) 0 0Non-guaranteed hours employees, number (Headcount) 0 0S1-6 Employee turnoverEmployee's who left NTG (Headcount), number 808 516Employee turnover (%) 23.2 18.8Entity specific Employee turnover, adjusted for synergies (%) 22.1 17.8**Gender as specified by the employees themselvesAccounting policies*To meet the ESRS requirements, NTG revised its reporting methodology in 2025 and now reports several data points using the headcount method. As comparable data for 2024 was not previously systematically collected, it is only available to a limited extent and therefore impractical to report any missing numbers.Full-time-equivalent (FTE)Full-time-equivalent is an employee whose weekly working hours are established in accordance with national legislation and customary practices pertaining to agreed-upon working time.HeadcountHeadcounts are defined as employees with a standard or temporary contract with NTG, including employees working, part-time, full-time and with non-guarantees working hours. Headcount comparison data for 2024 was not available.Country distribution and distribution by genderThe total number of employees and distribution by gender (headcount) split into country by countries in which NTG has 50 employees or more representing at least 10% of the total number of employees. Numbers reported as the end of the reporting period.Employees per contract type and genderNumber of employees (headcount) and divided by gender, and also reported as respective ratios. Numbers report-ed at the end of the reporting period.Permanent and temporary employeesThe total number of employees (headcount) divided by contract type. Numbers reported at the end of the report-ing period. Employee turnoverNumber of employees (headcount) who left NTG during the reporting period, including voluntary and involuntary leavers. The turnover rate is based on the total share of employees (headcount) who left NTG during the reporting period divided by the total number of employees.Employee turnover, adjusted for synergies (entity specific)Number of employees (headcount) who left NTG during the reporting period, adjusted for acquisition and merging terminations, relative to the number of employees reported at the end of the reporting period.S1-9 Diversity metricsNTG is committed to building a diverse workforce and leadership team, represented by a broad range of ages, nationalities, genders, and backgrounds. We believe diversity is a source of strength and innovation, enhancing creativity, problem-solving, and collaboration. Our global and local operations bring together individuals from different cultures and experiences, enabling us to deliver more innovative solutions and better meet the needs of our diverse customer base. Diversity fosters an inclusive and dynamic work environment where different perspectives are valued and respected.Our ESG & Diversity Policy reinforces this commitment by ensuring fair and objective treatment of all employees and applicants, based solely on criteria relevant to each position. This applies across all roles, including management, and reflects NTGâs zero-tolerance approach to discrimination. We aim to attract and retain talented employees by offering equal opportunities for growth and development.Executive Management diversityGender diversity at Executive Management level includes the Executive Management team and employees reporting directly to them with managerial responsibilities. In 2025, this group comprised 11 employees, with a gender distribution of 82% male and 18% female. NTG has consequently achieved its objective of reaching a representation of 10% of the underrepresented gender in Executive Management and direct reports well before 2027.We are proud of this progress and have now raised our ambition. A new target has been established to achieve at least 30% representation of the underrepresented gender by 2028.Board of DirectorsThe Board of Directors of the parent, NTG Nordic Transport Group A/S comprises seven members of which two are female (28.6%). The Board of Directors aims to have at least 40% of the underrepresented gender among the Board members by 30 June 2026, as this constitutes an even distribution in terms of gender in accordance with the definitions of the Danish Act on Gender Balance.When evaluating candidates for election or re-election to the Board of Directors, both the Nomination Committee and the Board of Directors consider a broad range of competencies, including diversity and other relevant criteria.S1-9 Composition of NTG's management levelsESRS ID 2025 2024Entity specific Board of DirectorsGender distribution in number of employees (head count) at top management level, female Directors 2 2Gender distribution in number of employees (head count) at top management level, male Directors 5 5Gender distribution of employees at top management level, female Directors (%) 28.6 28.6Gender distribution of employees at top management level, male Directors (%) 71.4 71.4Gender distribution in number of employees (head count) S1-9at top management levelGender distribution in number of employees (head count) at top management level, female top managers 2 1Gender distribution in number of employees (head count) at top management level, male top managers 9 10Gender distribution in percentage of employees at top S1-9management levelProportion of female (%) 18.2 9.1Proportion of male (%) 81.8 90.9Entity specific Other levels of managementProportion of female managers (%) 24.1 27.5Proportion of male managers (%) 75.9 72.5S1-9 More characteristics of NTG's employeesESRS ID 2025 2024S1-9 Age distributionDistribution of employees (headcount) under 30 years old (%) 23.0 24.5Distribution of employees (headcount) between 30 and 50 years old (%) 48.5 48.3Distribution of employees (headcount) over 50 years old (%) 28.5 27. 2Distribution of employees (headcount) under 30 years old (number) 801 719Distribution of employees (headcount) between 30 and 50 years old (number) 1,688 1,416Distribution of employees (headcount) over 50 years old (number) 994 797Entity specific Employee seniorityEmployee seniority <1 year (%) 19.5 20.6Employee seniority 1 - 3 years (%) 31.3 30.3Employee seniority 4 - 10 years (%) 29.8 30.0Employee seniority 11 - 25 years (%) 15.5 14.7Employee seniority >25 years (%) 4.1 4.5Gender balance in parent company Danish Financial Statements Act, section 107f % HeadcountBoard of Directors (female/male) 28.6/71.4 7Executive management (female/male) 0/100 2Other levels of management (female/male) 28.6/71.4 7Accounting policiesBoard of Directors (entity specific)Number of female and male members of the Board of Directors relative to the total numbers of the Board of Directors at the end of the reporting period. Top management Top management in NTG are defined as Executive Management and employees with employee responsibility who report directly to Executive Management. Number of female and male top managers relative to the total headcount of top managment at year end. Other levels of management, gender proportion (entity specific)Number of female and male managers relative to total managerial employees at the end of the reporting period. Managers are defined as employees with employee responsibility.Age distributionReported number of employees (Headcount) by age group relative to employees at the end of the reporting period.Employee seniority (entity specific)Reported number of employees by seniority level (Headcount) relative to employees at the end of the reporting period.Gender balance in parent companyThe Board of Directors of the parent, NTG Nordic Transport Group A/S comprises seven members of which two are female (28.6%). The Board of Directors aims to have at least 40% of the underrepresented gender among the Board members by 30 June 2026, as this constitutes an even distribution in terms of gender in accordance with the definitions of the Danish Act on Gender Balance. There are no employee-elected representatives in the Board of Directors.As the Executive management only constitutes 2 employees (male) which means that the proportion of the underrepresented gender is 0%.Other management levels in direct line to the Executive management employed in NTG Nordic Transport Group A/S comprises seven members of which two are female (28.6%). NTG has set a target to have at least 30% of the underrepresented gender among the other management levels by 2028 in accordance with the definitions of the Danish Act on Gender Balance.Achieving gender balanceWhen evaluating candidates for election or re-election to the Board of Directors, both the Nomination Committee and the Board of Directors consider a broad range of competencies, including diversity and other relevant criteria.We aim to increase the representation of the underrepresented gender within the two management levels below the Board of Directors. This objective reflects our ongoing commitment to fostering equal opportunities and promoting a diverse and inclusive leadership pipeline across the organisation. By strengthening our focus on balanced gender representation at senior levels, we seek to enhance decision-making, support long-term value creation, and reinforce our broader diversity ambitions.S1-14 Health and safety metricsEmployee safety is a top priority at NTG. We monitor key performance indicators (KPIs) focused on reduc-ing incidents that could cause physical or psycholog-ical harm during daily tasks. Our primary goal is to protect the well-being of all employees and prevent severe workplace injuries.The nature of our operations, being long-distance transport in dense traffic, handling heavy machinery and goods, and coordinating with multiple stakehold-ers carries inherent risks. While the transport industry can experience serious or even fatal accidents, NTG has never recorded a fatality, and we are committed to maintaining this record. Preventing severe accidents remains our highest priority.NTGâs entire workforce is covered by health and safe-ty management systems maintained at the local entity level. Each NTG entity reports the required health and safety data to Group biannually. All incidents are documented and analysed to identify root causes, and local management reviews findings to determine whether procedures should be revised or optimised. We recognise that accident severity often correlates with absence duration; therefore, we have set annual targets to reduce both the frequency of work-related incidents and the number of absence days caused by such accidents.The growth in NTGâs workforce in 2025 also influ-enced the total number of work-related accidents. The increase in both the number and rate of incidents re-flects the higher proportion of blue-collar employees in operational roles. The figures are further affected by acquisitions completed in late 2024, which are in-cluded for a full year, as well as additional acquisitions made in 2025.S1-14 Health and safety informationESRS ID 2025 2024S1-14Number of Number of fatalities in own workforce work-related as result of work-related injuries fatalitiesand work-related ill health 0 0Number of Number of fatalities as result of work-related work-related injuries and work-fatalities - other related ill health of other workers workersworking on undertaking's sites 0 0Number of work-related Number of recordable work-related accidentsaccidents for own workforce 54 25Rate of Rate of recordable work-related work-related accidents for own workforce, accidentsper million working hours 9.6 5.2*Rate of work-related accidents, salaried Rate of recordable work-related employees accidents for own workforce, salaried (Entity specific)employees per million working hours 1.1 0.6Rate of work-related accidents, Rate of recordable work-related Hourly workers accidents for own workforce, Hourly (Entity specific)workers per million working hours 27.9 15.1Number of work-related ill Number of cases of recordable healthwork-related ill health of employees 0 0Number of days lost to work-related injuries and fatalities from work-Number of days related accidents, work-related lost to work-ill health and fatalities from ill related injurieshealth related to employees 938 524ESRS ID 2025 2024S1-14Rate of days Rate of days lost to work-related lost to work-injuries resulting in more than one day related injuries, of absence per million working hours all employees scheduled in the reporting period, all (Entity specific)employees per million working hours 167.3 108.9Rate of days lost to work-related Rate of days lost to work-injuries resulting in more than related injuries, one day of absence per million salaried working hours scheduled in the employees reporting period, salaried employees (Entity specific)per million working hours 42.8 4.9Rate of days lost to work-related Rate of days injuries resulting in more than lost to work-one day of absence per million related injuries, working hours scheduled in the hourly workers reporting period, hourly workers (Entity specific)per million working hours 329.41 332.6Rate of unplanned absence (Entity specific) Unplanned absence Unplanned absence, total (%) 5.1 3.1Unplanned absence, Salaried employees (%) 3.3 2.1Unplanned absence, Hourly workers (%) 8.5 5.3Health and safety management Own workforce covered by health systemsand safety management systems (%) 100 100Accounting policies*The figure have been restated to reflect the improved data quality concerning reported number of workdays in 2024 resulting in a restatement of the previously reported rate (4.5). For more information se BP-2. Number of work-related fatalitiesReported number of fatalities in own workforce as result of work-related injuries and work-related ill health.Number of work-related fatalities - other workersReported number of fatalities as result of work-related injuries and work-related ill health of other workers working on NTG's sites.Number of work-related accidentsReported number of recordable work-related accidents for own workforce.Rate of work-related accidentsNumber of reported work-related injuries resulting in more than one day of absence for own workforce per million working hours.Rate of work-related accidents, salaried employees (Entity specific)Rate of recordable work-related accidents for own workforce, salaried employees per million working hours.Rate of work-related accidents, Hourly workers (Entity specific)Rate of recordable work-related accidents for own workforce, hourly employees per million working hours.Number of work-related ill healthReported number of cases of recordable work-related ill health of employees.Number of days lost to work-related injuriesReported number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health related to employees.Rate of days lost to work-related injuries, all employees (Entity specific) Number of reported days of absence due to work-related injuries resulting in more than one day of absence per million working hours scheduled in the reporting period, all employees.Rate of days lost to work-related injuries, salaried employees (Entity specific)Number of reported days of absence due to work-related injuries resulting in more than one day of absence per million working hours scheduled in the reporting period, salaried employees.Rate of days lost to work-related injuries, hourly workers (Entity specific) Number of reported days of absence due to work-related injuries resulting in more than one day of absence per million working hours scheduled in the reporting period, hourly workers.Rate of unplanned absence (Entity specific)Reported number of days of absence per FTE due to unplanned absence (in example illness unrelated to work) relative to the number of working days during the reporting period adjusted for maternity/paternity leave, agreed holidays and national public holidays.Own workforce covered by health and safety management systems All NTG's own workforce are covered by different locally maintained health and safety management systems. NTG entities report requested health and safety information to group on biannually basis.S1-17 Incidents, complaints and severe human rights impactsIn 2025 NTG recorded six whistleblower reports of harassment, all of which were interrelated. Because reporters did not respond to requests for information and the investigation disclosed no evidence of harassment, the reports were closed as unsubstantiated. Further, two whistleblower reports alleging potential corruption were investigated during a site visit, which included multiple interviews. No evidence indicated corruption and the reports were closed as unsubstantiated.S1-17 ESRS ID 2025 2024Incidents, complaints and severe human rights impactsS1-17_0 2 Number of incidents of discrimination 6 2S1-17_0 3 Number of complaints filed through channels for people in own workforce to raise concerns 2 2S1-17_0 4 Number of complaints filed to National Contact Points for OECD Multinational Enterprises 0 0S1-17_0 5 Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors 0 0S1-17_0 8 Number of severe human rights issues and incidents connected to own workforce 0 0S1-17_0 9 Number of severe human rights issues and incidents connected to own workforce that are cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises 0 0S1-17_11 Amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to own workforce 0 0Accounting policiesAccounting policies for S1-17 â Incidents, complaints and severe human rights impactS1-17_0 2 Number of incidents reported by employees in own workforce about incidents of discrimination and/or harassment due to gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination involving internal and/or external stakeholders arcoss operations.S1-17_0 3 Number of cases field through channels for employees in own workforce to raising concerns about incidents of other cases not relating to above mentioned subjects.S1-17_0 4 Information received by NTG on number of complaints filed to National Contact Points for OECD Multinational Enterprises.S1-17_0 5 Reported amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors.S1-17_0 8 Reported number of severe human rights issues and incidents connected to own workforce.S1-17_0 9 Reported number of severe human rights issues and incidents connected to own workforce that are cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises.S1-17_11 Reported amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to own workforce.ESRS S2Workers in value chainNTG has opted for the transitional relief available in ESRS 1 General requirements Appendix C for âwave 1â reporters. This includes an option to omit all information required by ESRS S2 Workers in the value chain.This implies however, that NTG will provide certain summarised information in accordance with ESRS 2 General disclosures, paragraph 17. The following section includes information about the outcome of NTGâs materiality assessment as well as information about policies, actions, and targets.As an asset-light freight forwarder, NTG relies heavily on third-party suppliers to deliver its services. Suppliers and their employees must be able to handle goods and transport units on NTGâs behalf while meeting agreed customer-specific quality criteria, procedures, and the requirements of NTGâs Supplier Code of Conduct.They must also be able to manage and mitigate any operational deviations in cooperation with NTG, customers, and other value-chain partners.Interest and views of our value chain workers are reflected in ESRS 2, SBM-2 on p. 46.Material impacts, risks and opportunities8The risk of forced labourNTG's global supplier network carries a risk of breaches of labour laws or international standards, including forced-labour practices such as restricting workersâ movement, withholding wages or documents, or requiring unpaid work. Such violations conflict with the ILO Core Conventions and UN Global Compact labour principles and may lead to financial or reputational harm for NTG.NTG manages these risks through its Supplier Code of Conduct, which sets clear expectations on human and labour rights. All suppliers must acknowledge the Code, and they are expected to ensure that their own subcontractors and agents comply.Despite these measures, residual risks remain. Parts of the global subcontractor network may not be fully covered, confirmations may be delayed, and NTG cannot directly oversee suppliersâ employment practices, meaning breaches may occur without NTGâs immediate knowledge.The 2024 acquisition of Freightzen Logistics, expanding NTGâs footprint in Southeast Asia, does not materially increase overall risk. Although certain countries in the region may pose concerns, the exposure remains limited as the region represents less than 1% of Group revenue.Policies related to value chain workersNTG expects all suppliers to meet the same ethical, human-rights, and labour standards that apply to NTGâs own employees, as set out in the Supplier Code of Conduct. The Board of Directors oversees the policy, with Executive Management and local managing directors responsible for implementation in supplier relationships.The Code sets requirements on responsible business conduct, including zero tolerance for bribery and corruption, respect for human and labour rights, health and safety, and access to NTGâs whistleblower system. Suppliers must identify, manage, and remediate any deviations and ensure that their own agents, sub-suppliers, and subcontractors comply.The policy applies to all suppliers and business partners acting on NTGâs behalf and complements applicable laws in the countries where they operate. Suppliers are informed of the Code during procurement, and compliance forms part of the selection and vetting process. Major supplier agreements are managed centrally, while local entities oversee due diligence for local relationships.As a signatory to the UN Global Compact, NTG integrates the Ten Principles into its policies and expects suppliers to uphold the same standards, including compliance with relevant trade control regulations.Forced labourSuppliers must comply with the Code of Conduct for and all applicable laws, and implement effective measures to prevent forced labour. They are required to uphold internationally recognised human rights and labour standards.Engagement and remediationBecause some suppliers operate under the NTG brand, non-compliance may significantly affect NTGâs reputation. Suppliers and their employees are encouraged to report concerns directly or anonymously through NTGâs independent whistleblower portal.If NTG causes a material adverse impact on a supplier or its workers, the company will work to provide appropriate remediation, including compensation where required.Actions and Target Setting NTG has not yet established specific actions or targets to address its material impacts on suppliers and their employees. As we have not systematically collected information from suppliers on the number or nature of potential forced-labour incidents, we will work with them to obtain a clearer understanding of the scale and characteristics of these impacts. This improved insight will enable NTG to define relevant actions and set realistic improvement targets. The process will begin in 2026.Governance informationESRS G1Business conductGovernance frameworkNTG is committed to conducting its business responsibly, ethically, and with full transparency, to fulfil our goals and our stakeholdersâ expectations for the highest standards of business integrity. We are dedicated to adhering to all applicable laws and regulations governing our business operations. As a publicly listed company with activities worldwide, we encounter a range of legal and regulatory challenges. In addition, our dependence on independent transport carriers raises internal and external compliance risks.IRO-1, G1 Material impacts, risks and opportunities and the process to identifyNTG has applied the same methodology outlined in IRO-1 on page 54 to identify and evaluate material impacts, risks, and opportunities related to actual and potential business conduct impacts arising from NTGâs own operations, and activities across upstream and downstream value chains. NTG has within the sub-topic of prevention and detection of corruption and bribery, identified a systemic risk in the transport and logistics sector that could potentially materialise in the short-, medium- and long-term.SBM3, G1 Most jurisdictions in which NTG operates have leg-islation prohibiting bribery of government officials, foreign public officials, and private commercial actors. In addition to national laws, international anti-corruption conventions apply across many of the regions where NTG operates. Such legislation prohibits direct and indirect payments, as well as offers or promises to provide something of value for a corrupt purpose to gain a business advantage.Despite these national and global frameworks, NTG remains exposed to corruption and bribery risks, particularly in countries with higher inherent risk profiles. This includes potential exposure to facilita-tion payments for permits, Customs clearance, and similar processes.As a global organisation with an extensive value chain, NTG has identified and assessed involvement in corruption or bribery as a material risk for NTG. Preserving our reputation and avoiding significant fines or penalties in the event of non-compliance is critically important.In identifying and assessing impacts, risks and op-portunities related to business conduct, NTG utilised input from its compliance programmes, evaluating this against insights from internal subject-matter experts acting as proxies for relevant stakeholder groups. NTG considered other sub-topics but deter-mined they were not material in NTGâs 2025 double materiality assessment.ESRS 2The role of the administrative, supervisory and management bodiesNTG has integrated its governance framework within the structure of its management and board structure.ESRS 2 GOV-1 The role of the administrative, supervisory and management bodiesResponsible and ethical business conduct is firmly embedded in NTGâs corporate culture and organisational structure. This commitment is reflected throughout the Group, with dedicated governance bodies and employees working to maintain a robust framework that mitigates the risk of corruption and bribery throughout our value chain. The most important elements of our compliance efforts are employeesâ support globally for those efforts and enabling them to understand what must, may and may not do.Board of DirectorsThe Board of Directors exercises ultimate responsibility for the Groupâs strategic management and organisation, including oversight of financial and material matters and business conduct. It sets the policy, strategy, and objectives for sustainability, encompassing ethical business practices and compliance.The composition of the Board of Directors and its permanent committees is designed to ensure a diverse range of competencies, enabling effective oversight of business conduct and related matters.Executive ManagementThe Executive Management is responsible for NTGâs day-to-day operations, ensuring compliance with applicable legislation and adherence to the Board of Directorâs guidelines and strategic direction. This includes implementing strategies set by the Board of Directors and reporting on operational performance.ESRS 2 G1 KPIs 2025 Progression Read moreAll salaried employees must *More than 100 We are updating the Code of Conduct training Page 95receive Code of Conduct employees received material, and therefore existing employees did not training every year.training, equivalent conduct full training session. Training will be resumed to 5% of all employeesfor all salaried employees in 2026.We commit to perform Completed our We performed ongoing control on the group of Page 95yearly compliance audits and yearly compliance suppliers with sanctions and embargoes as well as spot checks of suppliers are spot checkscompliance checks of groups of new suppliers upon performed through remote contract completion and engagement.audits, questionnaires and checklists.We commit to perform a Conducted We conducted our third legal compliance risk Page 95biannual legal compliance our third legal assessment across all NTG entities. The results of the risk assessment across all compliance risk 2025 risk assessment informed the mitigation plan, entities.assessmentensuring a continued focus on high-risk entities and legal compliance areas.Own IRO Upstreamoperation Downstream9Prevention and detection including training Riskâ â âExecutive Management oversees development and content of NTGâs Codes of Conduct for Employees and for Suppliers, and other business conduct policies. These policies are communicated from the top, with the CEO ensuring clear and consistent messaging across the organisation.The Executive Management teamâs composition is intended to ensure that NTG manages business conduct matters in alignment with strategies established by the Board of Directors.Administrative FunctionsThe Group functions managed by the Executive Management are responsible for developing, implementing, and maintaining policies, actions, targets, and metrics related to business conduct, drawing on extensive industry experience in compliance implementation.To ensure that our Code of Conduct and other elements of the Legal Compliance Programmes are well understood and consistently applied, in-person and online training are high priorities, as detailed below. New employees must read NTGâs Code of Conduct for Employees and complete training modules covering operational systems and compliance topics.NTGâs network of compliance championsRecognising that a strong compliance culture is fundamental to NTGâs success and integrity, NTG established a network of local compliance advisors known as compliance champions within subsidiaries in 2020. These champions serve as the first point of contact for local legal compliance queries, particularly regarding anti-corruption, foreign trade controls (sanctions and export controls), data privacy and competition law.The network operates with support from Group Management and plays a key role in integrating compliance into business processes. Compliance champions assist local management in aligning daily operations with legal requirements, increasing compliance awareness among employees, and encouraging the reporting of compliance concerns.In 2024, NTG appointed 29 champions in 18 coun-tries, tasked with raising awareness of legislative changes and internal control updates. This network will be revitalised in 2026 after a period when NTG had insufficient compliance resources to expand and coordinate its global activities.Functions at risk in NTGNTG has assessed that certain roles, especially sales and business development, which involve negotiating and concluding customer contracts, pose an increased risk of exposure to corruption and bribery. Additionally, all new employees are considered at risk until they have fully familiarised themselves with NTGâs rules of conduct and completed mandatory compliance training.*The training percentage is calculated as the number of trained employees divided by the total number of salaried employees.ESRS G1Business conduct policies and corporate cultureTo address business conduct-related risks and challenges, NTG has established a comprehensive Legal Compliance Program covering anti-corruption, foreign trade controls, competition law, and data privacy. The programme is designed to prevent, detect, and respond to potential legal violations, ensuring that compliance is embedded across our global operations and value chain.MDR-P, G1-1 Code of Conduct for EmployeesThe Code of Conduct for Employees reflects NTGâs commitment to responsible business practices and serves as the foundation for fostering a strong compli-ance culture across the organisation. It sets clear stan-dards for employees on key topics such as conflicts of interest, protection of trade secrets and confidential information, bribery and facilitation payments, foreign trade controls, and the acceptance of gifts and favours. Introduction to the Code is mandatory for all members of NTGâs workforce.While NTG trusts that employees strive to deliver excellent services and act as supportive colleagues, we recognise that situations may arise where the correct legal and ethical course of action is unclear. The Code of Conduct provides practical guidance for such scenarios, helping employees make decisions that are lawful, ethical, and aligned with NTGâs interests. Al-though the Code cannot cover every possible situation or detail every law and policy, it offers a framework for responsible decision-making that protects NTG, its employees, contractors, and stakeholders.Code of Conduct for SuppliersThe Code of Conduct for Suppliers underpins actions carried out for and on behalf of NTG, providing guid-ance to suppliers of goods and services on ethical busi-ness practices. It communicates NTGâs commitment to sustainability in areas such as human rights, anti-corrup-tion, labour standards, and environmental responsibility. Suppliers must uphold the same values and principles as NTG, and compliance is monitored through spot checks, subcontractor audits, and risk assessments.NTGâs stakeholders expect us to implement our core value of responsible behaviour throughout our supply chain and to conduct business ethically. The Suppli-er Code of Conductâs principles and requirements strengthen NTGâs supplier relationships and foster sustainable partnerships. Suppliers are also expected to ensure that their agents, sub-suppliers, and subcon-tractors comply with these requirements.Our Supplier Code will be available on NTGâs website in 12 languages notifying suppliers of NTGâs expecta-tions and is implemented contractually with suppliers.ESRS G1Prevention and detection of corruption and briberyNTG has established clear processes for risk assessment and operates an independent whistleblower system designed to prevent, detect, and address compliance challenges across the organisation.G1-3 Risk Assessment â A Fundamental ElementNTGâs internal risk assessment is a key tool for identifying and addressing compliance risks effectively. It highlights areas where potential non-compliance with laws, regulations, or internal policies may occur and evaluates the extent to which mitigating measures have been implemented.NTG conducts biannually a legal compliance risk assessment across all entities. An automated questionnaire is distributed to all managing directors, and the results are processed to form the mitigation plan, ensuring continued focus on high-risk entities and compliance areas.SPEAK UP!To prevent, detect, and address allegations or incidents of corruption or bribery, NTG operates an independent whistleblower system called SPEAK UP!. The system is administered by an external third party to guarantee anonymity. All reports are screened and assessed before being forwarded to the appropriate NTG representatives in line with the Whistleblower Policy. Every report is investigated, and each investigation concludes with a written report containing findings and recommendations for further action. Final reports are submitted to NTGâs Audit Committee.Training on Code of Conduct, policies, and legislation NTG prioritises training to ensure employees understand and comply with the Code of Conduct and other elements of the Legal Compliance Programme. The Code is provided to all employees upon joining and is accessible via NTGâs intranet and public website. Annual online training on the Code of Conduct is mandatory, and NTG monitors and reports on completion rates each year.MDR-A, G1-4 Online Compliance Training NTGâs online compliance training is designed to help employees recognise and mitigate risks in their daily work. Employees with computer access must complete online modules covering NTGâs Code of Conduct, and Anti-Corruption, Foreign Trade Controls, Data Privacy and Competition Law policies. Each module includes an introductory video by the Group CEO or Group Legal, a training video, and a test. New employees must read NTGâs Code of Conduct and attend training sessions related to operational systems.Due to restructuring of the Code of Conduct training programme and limited internal resources, NTG did not conduct full training sessions for all employees in 2025. This year NTG conducted in-person Code of Conduct Teams training for global MDs and in-person employee training during site visits at two entities. Remaining functions at risk have not received training due to the restructuring, but NTG will resume full, updated training for all employees in 2026.Supplier complianceNTG conducts ongoing compliance checks on supplier groups and other relevant parties regarding sanctions and embargoes, using automated screening tools integrated into transport management systems. Additional checks are performed on new suppliers upon contract completion and engagement.Confirmed incidents of corruption or briberyDuring the reporting period, NTG was not involved in any breaches, cases, convictions, or fines related to violations of anti-corruption or anti-bribery laws.MDR-T Tracking effectiveness through targetsTo continuously prevent and detect corruption and bribery, NTG has established targets to monitor progress towards responsible business practices.Annual Compliance TrainingOne key target is the annual completion of online compliance training for employees on NTGâs Code of Conduct, including employees in functions identified as high-risk as well as all other staff with daily computer access.Supplier Audits and Spot ChecksA second target is NTGâs commitment to conduct annual compliance audits and spot checks of suppliers through remote audits, questionnaires, and checklists. In addition to ongoing controls for sanctions and embargo compliance and checks on new suppliers, NTG plans to introduce spot checks to verify adherence to NTGâs Supplier Code of Conduct.Follow-Up on Risk AssessmentA third target is conducting follow-up sessions on the results of NTGâs 2025 internal risk assessment. Entities with high or medium risk profiles will be reviewed to monitor the effectiveness of mitigating measures implemented under NTGâs Legal Compliance Program. Risk profiles are based on an entityâs location (annual TI Corruption Perceptions Index), and/or compliance risks it faces, e.g., solicitation of bribes or facilitation payments, personal data breach. Additional informationESRS 2 IRO-2List of datapoints that derive from other EU legislationDisclosure requirement ESRS 2 IRO-2 paragraph 56 & ESRS 2 Appendix BDisclosure Requirement SFDR Pillar 3 EU Climate Page and related datapointreferencereference Benchmark Regulation referenceLaw reference CommentreferenceGeneralESRS 2 GOV-1 Board's gender diversity paragraph 21 (d) Indicator number 13 of Table #1 of Commission Delegated Regulation (EU) 35-36Annex 12020/1816 (27), Annex IIESRS 2 GOV-1 Percentage of board members who are Delegated Regulation (EU) 2020/1816, 32independent paragraph 21 (e)Annex IIESRS 2 GOV-4 Statement on due diligence paragraph 30 Indicator number 10 Table #3 of Annex 1 52ESRS 2 SBM-1 Involvement in activities related to fossil fuel Indicators number 4 Table #1 of Annex 1 Article 449a Regulation (EU) No Delegated Regulation (EU) 2020/1816, Not relevantactivities paragraph 40 (d) i575/2013; Commission Implementing Annex IIRegulation (EU) 2022/2453 (28) Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social riskESRS 2 SBM-1 Involvement in activities related to chemical Indicator number 9 Table #2 of Annex 1 Delegated Regulation (EU) 2020/1816, Not relevantproduction paragraph 40 (d) iiAnnex IIESRS 2 SBM-1 Involvement in activities related to Indicator number 14 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1818 Not relevantcontroversial weapons paragraph 40 (d) iii14, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex IIESRS 2 SBM-1 Involvement in activities related to cultivation Delegated Regulation (EU) 2020/1818, Not relevantand production of tobacco paragraph 40 (d) ivArticle 12(1) Delegated Regulation (EU) 2020/1816, Annex IIDisclosure Requirement SFDR Pillar 3 EU Climate Page and related datapointreferencereference Benchmark Regulation referenceLaw reference CommentreferenceEnvironmentESRS E1-1 Transition plan to reach climate neutrality by Regulation (EU) 2021/1119, Article 2(1) 582050 paragraph 14ESRS E1-1 Undertakings excluded from Paris-aligned Article 449a Regulation (EU) No Delegated Regulation (EU) 2020/1818, 58Benchmarks paragraph 16 (g)575/2013; Commission Implementing Article 12.1 (d) to (g), and Article 12.2Regulation (EU) 2022/2453 Template 1: Banking book Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturityESRS E1-4 GHG emission reduction targets paragraph 34 Indicator number 4 Table #2 of Annex 1 Article 449a Regulation (EU) No Delegated Regulation (EU) 2020/1818, 62575/2013; Commission Implementing Article 6Regulation (EU) 2022/2453 Template 3: Banking book â Climate change transition risk: alignment metricsESRS E1-5 Energy consumption from fossil sources Indicator number 5 Table #1 and 66disaggregated by sources (only high climate impact sectors) Indicator n. 5 Table #2 of Annex 1paragraph 38ESRS E1-5 Energy consumption and mix paragraph 37 Indicator number 5 Table #1 of Annex 1 66ESRS E1-5 Energy intensity associated with activities in high Indicator number 6 Table #1 of Annex 1 66climate impact sectors paragraphs 40 to 43ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions Indicators number 1 and 2 Table #1 of Article 449a; Regulation (EU) No Delegated Regulation (EU) 2020/1818, 63paragraph 44Annex 1575/2013; Commission Implementing Article 5(1), 6 and 8(1)Regulation (EU) 2022/2453 Template 1: Banking book - Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturityESRS E1-6 Gross GHG emissions intensity paragraphs 53 Indicators number 3 Table #1 of Annex 1 Article 449a Regulation (EU) No Delegated Regulation (EU) 2020/1818, 63to 55575/2013; Commission Implementing Article 8(1)Regulation (EU) 2022/2453 Template 3: Banking book - Climate change transition risk: alignment metricsESRS E1-7 GHG removals and carbon credits paragraph 56 Regulation (EU) 2021/1119, Article 2(1) Not relevantESRS E1-9 Exposure of the benchmark portfolio to climate-Delegated Regulation (EU) 2020/1818, Not materialrelated physical risks paragraph 66Annex II Delegated Regulation (EU) 2020/1816, Annex IIESRS E1-9 Disaggregation of monetary amounts by acute Article 449a Regulation (EU) No Not materialand chronic physical risk paragraph 66 (a) ESRS E1-9 575/2013; Commission Implementing Location of significant assets at material physical risk Regulation (EU) 2022/2453 paragraphs paragraph 66 (c).46 and 47; Template 5: Banking book - Climate change physical risk: Exposures subject to physical risk.Disclosure Requirement SFDR Pillar 3 EU Climate Page and related datapointreferencereference Benchmark Regulation referenceLaw reference CommentreferenceESRS E1-9 Breakdown of the carrying value of its real estate Article 449a Regulation (EU) No Not materialassets by energy- efficiency classes paragraph 67 (c).575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraph 34; Template 2: Banking book -Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateralESRS E1-9 Degree of exposure of the portfolio to climate- Delegated Regulation (EU) 2020/1818, Not relevantrelated opportunities paragraph 69Annex IIESRS E2-4 Amount of each pollutant listed in Annex II of the Indicator number 8 Table #1 of Annex 1 69EPRTR Regulation (European Pollutant Release and Transfer Indicator number 2 Table #2 of Annex 1 Register) emitted to air, water and soil, paragraph 28Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1ESRS E3-1 Water and marine resources paragraph 9 Indicator number 7 Table #2 of Annex 1 Not materialESRS E3-1 Dedicated policy paragraph 13 Indicator number 8 Table 2 of Annex 1 Not materialESRS E3-1 Sustainable oceans and seas paragraph 14 Indicator number 12 Table #2 of Annex 1 Not materialESRS E3-4 Total water recycled and reused paragraph 28 (c) Indicator number 6.2 Table #2 of Annex Not material1ESRS E3-4 Total water consumption in m 3 per net revenue Indicator number 6.1 Table #2 of Annex 1 Not materialon own operations paragraph 29ESRS 2- IRO 1 - E4 paragraph 16 (a) i Indicator number 7 Table #1 of Annex 1 Not materialESRS 2- IRO 1 - E4 paragraph 16 (b) Indicator number 10 Table #2 of Annex 1 Not materialESRS 2- IRO 1 - E4 paragraph 16 (c) Indicator number 14 Table #2 of Annex 1 Not materialESRS E4-2 Sustainable land / agriculture practices or policies Indicator number 11 Table #2 of Annex 1 Not materialparagraph 24 (b)ESRS E4-2 Sustainable oceans / seas practices or policies Indicator number 12 Table #2 of Annex 1 Not materialparagraph 24 (c)ESRS E4-2 Policies to address deforestation paragraph 24 (d) Indicator number 15 Table #2 of Annex 1 Not materialESRS E5-5 Non-recycled waste paragraph 37 (d) Indicator number 13 Table #2 of Annex 1 Not materialESRS E5-5 Hazardous waste and radioactive waste Indicator number 9 Table #1 of Annex 1 Not materialparagraph 39Disclosure Requirement SFDR Pillar 3 EU Climate Page and related datapointreferencereference Benchmark Regulation referenceLaw reference CommentreferenceSocialESRS 2- SBM3 - S1 Risk of incidents of forced labour Indicator number 13 Table #3 of Annex I 78paragraph 14 (f)ESRS 2- SBM3 - S1 Risk of incidents of child labour Indicator number 12 Table #3 of Annex I 79paragraph 14 (g)ESRS S1-1 Human rights policy commitments paragraph 20 Indicator number 9 Table #3 and 79Indicator number 11 Table #1 of Annex IESRS S1-1 Due diligence policies on issues addressed by the Delegated Regulation (EU) 2020/1816, 79fundamental International Labor Organisation Conventions Annex II1 to 8, paragraph 21ESRS S1-1 processes and measures for preventing trafficking Indicator number 11 Table #3 of Annex I 79in human beings paragraph 22ESRS S1-1 workplace accident prevention policy or Indicator number 1 Table #3 of Annex I 79management system paragraph 23ESRS S1-3 grievance/complaints handling mechanisms Indicator number 5 Table #3 of Annex I 80paragraph 32 (c)ESRS S1-14 Number of fatalities and number and rate of Indicator number 2 Table #3 of Annex I Delegated Regulation (EU) 2020/1816, 85work-related accidents paragraph 88 (b) and (c)Annex IIESRS S1-14 Number of days lost to injuries, accidents, Indicator number 3 Table #3 of Annex I 85fatalities or illness paragraph 88 (e)ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) Indicator number 12 Table #1 of Annex I Delegated Regulation (EU) 2020/1816, Not materialAnnex IIESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) Indicator number 8 Table #3 of Annex I Not materialESRS S1-17 Incidents of discrimination paragraph 103 (a) Indicator number 7 Table #3 of Annex I 87ESRS S1-17 Non-respect of UNGPs on Business and Human Indicator number 10 Table #1 and Delegated Regulation (EU) 2020/1816, 87Rights and OECD paragraph 104 (a)Indicator n. 14 Table #3 of Annex IAnnex II Delegated Regulation (EU) 2020/1818 Art 12 (1)ESRS S2-1 Policies related to value chain workers paragraph Indicator number 11 and n. 4 Table #3 of 8918Annex 1ESRS S2-1 Non-respect of UNGPs on Business and Human Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, 89Rights principles and OECD guidelines paragraph 19Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)ESRS S2-1 Due diligence policies on issues addressed by the Delegated Regulation (EU) 2020/1816, 89fundamental International Labor Organisation Conventions Annex II1 to 8, paragraph 19ESRS S3-1 Human rights policy commitments paragraph 16 Indicator number 9 Table #3 of Annex Not material1 and Indicator number 11 Table #1 of Annex 1Disclosure Requirement SFDR Pillar 3 EU Climate Page and related datapointreferencereference Benchmark Regulation referenceLaw reference CommentreferenceESRS S3-1 non- respect of UNGPs on Business and Human Indicator number 10 Table #1 Annex 1 Delegated Regulation (EU) 2020/1816, Not materialRights, ILO principles or and OECD guidelines paragraph 17Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)ESRS S3-4 Human rights issues and incidents paragraph 36 Indicator number 14 Table #3 of Annex 1 Not materialESRS S4-1 Policies related to consumers and end-users Indicator number 9 Table #3 and Not materialparagraph 16Indicator number 11 Table #1 of Annex 1ESRS S4-1 Non-respect of UNGPs on Business and Human Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, Not materialRights and OECD guidelines paragraph 17Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) 31ESRS S4-4 Human rights issues and incidents paragraph 35 Indicator number 14 Table #3 of Annex 1 Not materialGovernanceESRS G1-1 United Nations Convention against Corruption Indicator number 15 Table #3 of Annex 1 94paragraph 10 (b)ESRS G1-1 Protection of whistle-blowers paragraph 10 (d) Indicator number 6 Table #3 of Annex 1 95ESRS G1-4 Fines for violation of anti-corruption and anti-Indicator number 17 Table #3 of Annex 1 Delegated Regulation (EU) 2020/1816, 95bribery laws paragraph 24 (a)Annex IIESRS G1-4 Standards of anti-corruption and anti-bribery Indicator number 16 Table #3 of Annex 1 95paragraph 24 (b)Notes</mrv:SustainabilityReport>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx-1" id="f0__s11__7__10" xml:lang="en">EU TaxonomyThe EU Taxonomy for sustainable activities is the EUâs classification system for identifying economic activities that make a substantial contribution to environmental sustainability.As a listed company, NTG must report in accordance with the EU Taxonomy Delegated Acts (EU) 2020/852, as amended by Delegated Regulation (EU) 2026/73, aligned with the EU Omnibus simplification package. In line with the amendment, we have chosen to apply the updated quantitative materiality thresholds and the simplified reporting tables..Taxonomy-eligible activities NTGâs core activities as an asset-light freight forwarder and logistics provider are currently not eligible the Taxonomy. Because taxonomy eligibility is assigned to the operator of the transport activity, NTG records taxonomy-eligible investment and operating costs. Our reviewing of our operations identified a limited number of sub-activities that qualify as taxonomy-eligible as they meet the substantial contribution criteria under the EU Taxonomy framework within our 2025 revenue taxonomy-eligible activities. Within our 2025 capital expenditure (capex) and operational expenditure (opex), NTG identified noteworthy taxonomy-aligned activities related to a number of economic activities.Taxonomy-aligned activitiesThe identified 2025 revenue taxonomy-eligible activities do not qualify as taxonomy-aligned activities as they do not relate to our cores activities. Collectively these activities constitute less than the 10% materiality threshold of our total revenue and we have waived the screening criteria for these activities. This in accordance with the amendments to (EU) 2021/2178 adopted by Delegated Regulation (EU) 2026/73.In 2025, NTGâs taxonomy-eligible capital expenditures accounted for 13.4% and taxonomy-eligible operating expenditures for 35.8%. These activities primarily relate to day-to-day investments, operations and maintenance of our own trucks. Taxonomy-aligned activities mainly derive from investments, operating expenses and maintenance costs associated with electric and plug-in hybrid company cars as well as electric trucks.Proportion of revenue (turnover), capex and opexBreakdown by environmental objectives of Taxonomy aligned activities KPIRevenue (turnover) 11,377 - - - - - - - - - - - - 90.1 1.0%Capex555 13.4% 15.1 2.7% 2.7% - - - - - 2.5% - 15.6 2.4%Opex204 35.8% 6.5 3.2% 3.2% - - - - - 0.1% 2.6% - 3.2 2.8%Proportion of EU Taxonomy - aligned capexEnvironmental objective of Taxonomy aligned activitiesEconomic activities Transport by motorbikes, passenger cars CCM 6.5 3.3% 14.1 2.5% 2.5% - - - - - T 77.0%and light commercial vehiclesFreight transport services by roadCCM 6.6 9.9% 0.0 0.0% 0.0% - - - - - 0.0%Installation, maintenance and repair of CCM 7.3 0.2% 0.9 0.2% 0.2% - - - - - 100.0%energy efficiency equipmentInstallation, maintenance and repair of charging stations for electric vehicles in buildings (and CCM 7.4 0.0% 0.1 0.0% 0.0% - - - - - E 100.0%parking spaces attached to buildings)Sum of alignment per objective2.7% - - - - -Total KPI 13.4% 15.1 2.7% 2.7% - - - - - 72.0%Proportion of EU Taxonomy â aligned opexEnvironmental objective of Taxonomy aligned activitiesEconomic activities Transport by motorbikes, passenger cars CCM 6.5 5.3% 5.3 2.6% 2.6% - - - - - T 49.2%and light commercial vehiclesFreight transport services by roadCCM 6.6 29.9% 0.1 0.0% 0.0% - - - - - 0.0%Installation, maintenance and repair of CCM 7.3 0.5% 1.0 0.5% 0.5% - - - - - 100.0%energy efficiency equipmentInstallation, maintenance and repair of charging stations for electric vehicles in buildings (and CCM 7.4 0.1% 0.2 0.1% 0.1% - - - - - E 100.0%parking spaces attached to buildings)Sum of alignment per objective3.2% - - - - -Total KPI 35.8% 6.5 3.2% 3.2% - - - - - 65.5%EU TaxonomyAccounting policyIdentification of taxonomy-eligible activitiesAlthough NTGâs core freight-forwarding activ-ities are not covered by the EU Taxonomy, we have identified other economic activities that qualify as taxonomy-eligible. These activities contribute to the climate objectives through their own performance, by enabling low-car-bon solutions, or by supporting the transition to a climate-neutral economy.From eligible to alignedFor each eligible activity, NTG determined the share of revenue, operating expenses (opex), and capital expenditures (capex) that qualify as taxonomy-eligible and taxonomy-aligned.Technical Screening CriteriaTo determine alignment, each eligible activity was assessed against the Technical Screening Criteria (TSC), including Substantial Contribu-tion and Do No Significant Harm (DNSH).For DNSH, we evaluated compliance with the criteria set out in the Annexes to the Climate Delegated Acts. Each DNSH requirement was reviewed individually for each activity, and only activities assessed as compliant were included. The assessment was based on desk-top research, professional judgement, and input from NTG subsidiaries on the specific nature of activities. Further detail on the TSC assessment is provided in the table on the following page.Minimum SafeguardsWe also assessed, at an aggregated level, whether all eligible and aligned activities comply with the EU Taxonomy Minimum Safe-guards. This requires companies to maintain procedures consistent with the OECD Guide-lines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, as well as with the principles and rightsset out in the ILO fundamental conventions and the International Bill of Human Rights.NTG has implemented several Codes of Conduct, a Legal Compliance Program, and policies on ESG, diversity, and whistleblowing. We identify, assess, and address actual and potential adverse impacts on human rights and other sustainability risks across our operations, supply chains, and business rela-tionships through a risk-based due diligence framework.These policies - published on our website - embed responsible business conduct and reflect NTGâs commitment to the principles and standards underpinning the Minimum Safeguards, including the DNSH criteria. On this basis, NTG considers its aligned economic activities to be compliant with the Minimum Safeguards.Double countingNone of the identified economic activities contribute to more than one environmental objective; all contribute solely to climate change mitigation. Revenue, opex, and capex are recorded once only within the respec-tive KPI numerators, and no overlaps occur between activities or associated financial amounts.Assessment of eligibility and technical screening criteriaTechnical Screening CriteriaActivity Eligibility Substantial Contribution DNSH6.5 Transport by motorbikes, The eligible activity relates to our leasing and operation of several The aligned activity is related to company cars that are powered by The activityâs compliance is assessed against the criteria described in the passenger cars and light company cars that comply with the EU emission standards EURO 5 and 6.electricity and plugin-hybrid electric vehicles (PHEV) with emissions Annex A: Generic criteria for DNSH to climate change adaptation. There below 50g CO/km. From 1 January 2026, only zero emission vehicles is no apparent physical climate risk for this activity. As the vehicles are commercial vehicles2qualify the Substantial Contribution.standard EU type-approved models, they are assumed to comply with the EU thresholds of reusability, recyclability and pollution.6.6 Freight transport The eligible activity relates to NTG entities leasing and operation of To be aligned, the vehicles are required to have zero tailpipe The activityâs compliance is assessed against the criteria described in services by roadvehicles falling under the scope of the EU emission standards EURO 6 emissions while in operation. One of the eligible vehicles is an electric Annex A: Generic criteria for DNSH to climate change adaptation. There and performing dedicated freight transport services for customers. truck, which has zero tailpipe emissions.is no apparent physical climate risk associated with this activity. As the vehicle is a standard EU type-approved model, it is assumed to comply with the EU thresholds for reusability, recyclability, and pollution.7.3 Installation, maintenance The eligible activity relates to our leasing and operation of buildings To be aligned the activities must comply with minimum requirements The activityâs compliance is assessed against the criteria described in and repair of energy efficiency and renovation measures related to installation, maintenance or repair set for individual components and systems and must relate to one of the annex A: Generic criteria for DNSH to climate change adaptation of energy efficiency equipment.the measures listed under the Substantial Contribution Criteria (a-f).(physical climate risks), and the Annex C: Generic criteria for DNSH equipment in buildingsto pollution prevention and control regarding use and presence of chemicals. It is assumed that the manufacturers of the equipment comply with applicable legislation. Further, it is assessed if the building in question is not dedicated to extraction, storage, transport or manufacture of fossil fuels.7.4 Installation, maintenance The eligible activity relates to installation and maintenance of charging This activity automatically fulfils the Substantial Contribution Criteria The activityâs compliance is assessed against the criteria described in the and repair of charging stations for electric vehicles on some of our premises.to climate change mitigation.annex A: Generic criteria for DNSH to climate change adaptation (physical climate risks). There is no apparent physical climate risk for this activity.stations for electric vehiclesAccounting policy for EU Taxonomy KPIsCapexThe capex KPI is calculated in accordance with âANNEX I â KPIâs of non-financial undertakingsâ.Capex means additions to intangible and tangible fixed assets, including additions from business combinations, consistent with the accounting principles of the NTG Annual Report 2024 (notes 5.1-5.3). Capex includes additions of right of use assets, in accordance with IFRS 16. Capex related to taxonomy-eligible (6.5, 6.6, 7.3, and 7.4) and taxonomy-aligned (6.5, 7.3, and 7.4) activi-ties are included in the numerator.NumeratorCapex reported in the numerator is all relat-ed to individual investments and is not part of a larger capex plan. Capex specifically included relates to right of use asset addi-tions related to company cars and trucks as well as installation of solar panels, energy efficiency equipment and electric vehicle charging stations.DenominatorThe denominator comprises all additions to intangible and tangible assets in accordance with notes 5.1-5.3 of the NTG Annual Re-port 2025 (incl. business combinations and IFRS 16 right of use assets).OpexThe opex KPI is calculated in accordance with âANNEX I â KPIâs of non-financial undertakingsâ.Opex means expenditures reported as part of direct costs or other external expenses in the income statement of NTG Group, in accordance with the accounting principles of the NTG Annual Report 2025.Numerator Opex related to taxonomy-eligible (6.5, 6.6, 7.3 and 7.4) and taxonomy-aligned (6.5, 7.3 and 7.4) activities are included in the numerator. Opex reported in the numerator is related to individual expenses and is not part of a larger capex plan. Opex specifically included relates to operation and maintenance costs of company cars, trucks, energy efficiency equipment and solar panels.DenominatorOpex included in the denominator (and numerator) is limited to direct non-capital-ised costs that relate to building renovation measures, short-term leases, maintenance and repair, and other direct expenditures relating to the day-to-day servicing of assets of property, plant and equipment. Opex groups included are warehouse, facility, car, truck, and trailer expenses.</mrv:DescriptionofTheTaxonomyRegulation>
<fsa:AverageNumberOfEmployees contextRef="ctx-1"
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<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx-1" id="f0__s11__7__166" xml:lang="en">Statement of the Board of Directors and the Executive ManagementThe Board of Directors and Executive Management have considered and adopted the Annual Report of NTG Nordic Transport Group A/S for the financial year 1 January - 31 December 2025.The Consolidated Financial Statements have been prepared in accordance with International Financial Reporting Standards as adopted by the EU and further requirements in the Danish Financial Statements Act, and the Parent Company Financial Statements have been prepared in accordance with the Danish Financial Statements Act. Managementâs Review has been prepared in accordance with the Danish Financial Statements Act. In our opinion, the Consolidated Financial Statements and the Parent Company Financial Statements give a true and fair view of the financial position at 31 December 2025 of the Group and the Parent Company and of the results of the Group and Parent Company operations and consolidated cash flows for the financial year 1 January - 31 December 2025.In our opinion, Managementâs Review includes a true and fair account of the development in the operations and financial circumstances of the Group and the Parent Company, of the results for the year and of the financial position of the Group and the Parent Company as well as a description of the most significant risks and elements of uncertainty facing the Group and the Parent Company.Additionally, the Sustainability statement, which is part of Management review, has been prepared, in all material respects, in accordance with paragraph 99a of the Danish Financial Statements Act. This includes compliance with the European Sustainability Reporting Standards (ESRS) including that the process undertaken by Management to identify the reported information (the âProcessâ) is in accordance with the description set out in the subsection "Processes to identify and assess material IRO's" in the "General" section of the Sustainability statement. Furthermore, disclosures in the subsection "EU taxonomy" in the "Environment" section of the Sustainability statement are, in all material respects, in accordance with Article 8 of EU Regulation 2020/852 (the âTaxonomy Regulationâ).The year 2025 marks the initial implementation of paragraph 99a of the Danish Financial Statements Act concerning compliance with the ESRS. As such, more clear guidance and practice are anticipated in various areas, which are expected to be issued in the coming years. Furthermore, the sustainability statement includes forward-looking statements based on disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected. In our opinion, the Annual Report of NTG Nordic Transport Group A/S for the financial year 1 January to 31 December 2025 with the file name NTG-2025-12-31-en.zip is prepared, in all material respects, in compliance with the ESEF Regulation.We recommend that the Annual Report be adopted at the Annual General Meeting.</sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx-1" id="f0__s11__7__167" xml:lang="en">Hvidovre</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx-1" id="f0__s11__7__168">2026-03-04</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-37" id="f0__s11__7__169" xml:lang="en">Mathias Jensen-Vinstrup</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-38" id="f0__s11__7__171" xml:lang="en">Christian D. Jakobsen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-37" id="f0__s11__7__170" xml:lang="en">Group CEO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-38" id="f0__s11__7__172" xml:lang="en">Group CFO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-39" id="f0__s11__7__173" xml:lang="en">Eivind Kolding</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-40" id="f0__s11__7__175" xml:lang="en">Jørgen Hansen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-41" id="f0__s11__7__177" xml:lang="en">Finn Skovbo Pedersen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-39" id="f0__s11__7__174" xml:lang="en">Chairman</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-40" id="f0__s11__7__176" xml:lang="en">Deputy chairman</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-42" id="f0__s11__7__179" xml:lang="en">Jesper Præstensgaard</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-43" id="f0__s11__7__181" xml:lang="en">Carsten Krogsgaard Thomsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-44" id="f0__s11__7__183" xml:lang="en">Louise Knauer</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-45" id="f0__s11__7__185" xml:lang="en">Lene Borne</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="f0__s11__7__189" xml:lang="en">To the shareholders of NTG Nordic Transport Group A/S</arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:AuditorsReportOnFinancialStatements contextRef="ctx-1" id="f0__s11__7__190" xml:lang="en">Report on the audit of the Financial Statements</arr:AuditorsReportOnFinancialStatements>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx-1" id="f0__s11__7__191" xml:lang="en">Our opinionIn 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 the Groupâs operations and cash flows for the financial year 1 January to 31 December 2025 in accordance with IFRS Accounting Standards as adopted by the EU and further requirements in the Danish Financial Statements Act. Moreover, in our opinion, the Parent Company Financial Statements give a true and fair view of the Parent Companyâs financial position at 31 December 2025 and of the results of the Parent Companyâs operations for the financial year 1 January to 31 December 2025 in accordance with the Danish Financial Statements Act.Our opinion is consistent with our Auditorâs Long-form Report to the Audit Committee and the Board of Directors.What we have auditedThe Consolidated Financial Statements (pp 103-135) and the Parent Company Financial Statements (pp 138-144) of NTG Nordic Transport Group A/S for the financial year 1 January to 31 December 2025 comprise income statement, balance sheet, statement of changes in equity and notes, including material accounting policy information for the Group as well as for the Parent Company and statement of comprehensive income and cash flow statement for the Group. Collectively referred to as the âFinancial Statementsâ.</arr:OpinionOnAuditedFinancialStatements>
<arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx-1" id="f0__s11__7__192" 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 Auditorâs responsibilities for the audit of the Financial Statements section of our report.We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.IndependenceWe are independent of the Group in accordance with the International Ethics Standards Board for 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. We have also fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code.To the best of our knowledge and belief, prohibited non-audit services referred to in Article 5(1) of Regulation (EU) No 537/2014 were not provided.AppointmentWe were first appointed auditors of NTG Nordic Transport Group A/S on 16 April 2020 for the financial year 2020. We have been reappointed annually by shareholder resolution for a total period of uninterrupted engagement of six years including the financial year 2025.</arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:KeyAuditMattersAudit contextRef="ctx-1" id="f0__s11__7__193" xml:lang="en">Key audit mattersKey audit matters are those matters that, in our professional judgement, were of most significance in our audit of the Financial Statements for 2025. These matters were addressed in the context of our audit of the Financial Statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.Key audit matterAccrued revenue and accrued cost of services The Groupâs revenue consists primarily of services, i.e. transportation of goods between destinations, which by nature are rendered over a period of time. The determination of the timing of revenue recognition is dependent on the application of the Groupâs accounting policies and the terms of customer contracts.The process of accruing for services rendered around the balance sheet date is complex and dependent on IT controls in certain operational IT systems due to a substantial number of transactions. Moreover, in the Air & Ocean division, a higher estimation uncertainty exists regarding recognising revenue in the right period at year-end due to the services being rendered over a lengthier period of time.We focused on this area because, at year end, accrued revenue and accrued cost of services involve significant accounting estimates which are complex by nature, and which rely on methods, data and assumptions applied by Management.Reference is made to notes 2.1 and 2.2 to the Consolidated Financial Statements and note 1 of the Parent Company Financial Statements.Business combinationsDuring the year, the Group completed business combinations with a total purchase price of DKK 1,076 million, of which the most significant ones were the acquisitions of ITC Logistic GmbH and DTK BE Holding ApS.Accounting for business combinations requires significant management judgement, particularly in relation to the identification and recognition of acquired assets and liabilities, including the assessment of whether contingent consideration, such as earn-out arrangements, should be recognised at the acquisition date.While the valuation techniques applied were not complex, the accounting involved judgement in determining whether contractual terms gave rise to identifiable liabilities and in assessing the appropriate recognition of such items in accordance with IFRS. We focussed on the two transactions due to the significance hereof and the level of judgement applied by Management.Reference is made to note 7.1 to the Consolidated Financial Statements.How our audit addressed the key audit matterWe performed risk assessment procedures to obtain an understanding of IT systems, business processes, and relevant controls regarding revenue and accrued costs. For the controls, we assessed whether they were designed and implemented to effectively address the risk of material misstatement.Our audit procedures included considering the appropriateness of the accounting policies for revenue recognition applied by Management and assessing compliance with IFRS Accounting Standards.For accrued revenue and accrued costs of services, we examined reports concerning services in progress and challenged the assumptions made by Management. We performed analytical procedures and tested input data used in Managementâs run-off analysis to evaluate the accuracy of the estimates made.We selected a sample of transactions around year-end and traced these to underlying evidence, including proof of delivery, to determine whether revenue and the related costs were recognised in the correct period.In addition, we applied data analysis in our testing of revenue transactions to identify and assess transactions outside the ordinary transaction flow.Our audit procedures included assessing the appropriateness of the accounting policies for business combinations and evaluating compliance with IFRS Accounting Standards. We involved our internal valuation specialists to assist in the assessment of Managementâs identification and recognition of acquired assets and liabilities, including the assessment of contingent consideration. We challenged Managementâs significant judgements, including those related to whether contingent considerations met the criteria for recognition as liabilities at the acquisition date.We reconciled the purchase consideration to the respective Share Purchase Agreements and traced cash payments to bank statements. We also assessed whether deferred and contingent consideration was accounted for in accordance with the contractual terms and evaluated Managementâs assessment of the underlying judgements applied. For consideration settled in shares, we reconciled the share-based consideration to the Share Purchase Agreement, verified the calculation of the number of shares transferred and confirmed that the share price applied was consistent with the terms of the agreement.We performed procedures on the opening balance sheets of the acquired entities, focusing on the most significant components within each acquired group.Finally, we assessed the adequacy of disclosures relating to the business combinations.</arr:KeyAuditMattersAudit>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="f0__s11__7__194" xml:lang="en">Statement on Managementâs ReviewManagement is responsible for Managementâs Review (pp 4-41 and 136).Our opinion on the Financial Statements does not cover Managementâs Review, and we do not as part of the audit express any form of assurance conclusion thereon.In connection with our audit of the Financial Statements, our responsibility is to read Managementâs Review and, in doing so, consider whether Managementâs Review is materially inconsistent with the Financial Statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated. Moreover, we considered whether Managementâs Review includes the disclosures required by the Danish Financial Statements Act. This does not include the requirements in paragraph 99 a related to the sustainability statement covered by the separate auditorâs limited assurance report hereon.Based on the work we have performed, in our view, Managementâs Review is in accordance with the Consolidated Financial Statements and the Parent Company Financial Statements and has been prepared in accordance with the requirements of the Danish Financial Statements Act, except for the requirements in paragraph 99 a related to the sustainability statement, cf. above. We did not identify any material misstatement in Managementâs Review.</arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx-1" id="f0__s11__7__195" 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 adopted by the EU and further requirements in the Danish Financial Statements Act and for the preparation of parent company financial statements that give a true and fair view in accordance with the Danish Financial Statements Act, and for such internal control as Management determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.In preparing the Financial Statements, Management is responsible for assessing the Groupâs and the Parent Companyâs ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless Management either intends to liquidate the Group or the Parent Company or to cease operations, or has no realistic alternative but to do so.</arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx-1" id="f0__s11__7__196" xml:lang="en">Auditorâs responsibilities for the audit of the Financial StatementsOur objectives are to obtain reasonable assurance about whether the Financial Statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditorâs report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs and the additional requirements applicable in Denmark will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these Financial Statements.As part of an audit in accordance with ISAs and the additional requirements applicable in Denmark, we exercise professional judgement and maintain professional scepticism throughout the audit. We also: · Identify and assess the risks of material misstatement of the Financial Statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. · Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Groupâs and the Parent Companyâs 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 and based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Groupâs and the Parent Companyâs ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditorâs report to the related disclosures in the Financial Statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditorâs report. However, future events or conditions may cause the Group or the Parent Company to cease to continue as a going concern. · Evaluate the overall presentation, structure and content of the Financial Statements, including the disclosures, and whether the Financial Statements represent the underlying transactions and events in a manner that gives a true and fair view. · Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial information of the entities or business units within the group as a basis for forming an opinion on the Consolidated Financial Statements. We are responsible for the direction, supervision and review of the audit work performed for purposes of the group audit. We remain solely responsible for our audit opinion.We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence and, where applicable, actions taken to eliminate threats or safeguards applied.From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Financial Statements of the current period and are therefore the key audit matters. We describe these matters in our auditorâs report unless law or regulation precludes public disclosure about the matter.</arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx-1" id="f0__s11__7__197" xml:lang="en">Report on compliance with the ESEF RegulationAs part of our audit of the Financial Statements we performed procedures to express an opinion on whether the annual report of NTG Nordic Transport Group A/S for the financial year 1 January to 31 December 2025 with the filename NTG-2025-12-31-en.zip is prepared, in all material respects, in compliance with the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) which includes requirements related to the preparation of the annual report in XHTML format and iXBRL tagging of the Consolidated Financial Statements including notes.Management is responsible for preparing an annual report that complies with the ESEF Regulation. This responsibility includes:· The preparing of the annual report in XHTML format;· The selection and application of appropriate iXBRL tags, including extensions to the ESEF taxonomy and the anchoring thereof to elements in the taxonomy, for all financial 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 NTG Nordic Transport Group A/S for the financial year 1 January to 31 December 2025 with the file name NTG-2025-12-31-en.zip is prepared, in all material respects, in compliance with the ESEF Regulation.</arr:AuditorsReportOnXbrlTagging>
<arr:SignatureOfAuditorsPlace contextRef="ctx-1" id="f0__s11__7__198" xml:lang="en">Hellerup</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx-1" id="f0__s11__7__199">2026-03-04</arr:SignatureOfAuditorsDate>
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<cmn:NameAndSurnameOfAuditor contextRef="ctx-46" id="f0__s11__7__202" xml:lang="en">Tue Stensgård Sørensen</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx-46" id="f0__s11__7__203" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
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<cmn:NameAndSurnameOfAuditor contextRef="ctx-47" id="f0__s11__7__207" xml:lang="en">Jacob Brinc h</cmn:NameAndSurnameOfAuditor>
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<arr:AuditorsReportOnSubstainabilityReport contextRef="ctx-1" id="f0__s11__7__211" xml:lang="en">Independent auditorâs limited assurance report on the sustainability statementTo the stakeholders of NTG Nordic Transport Group A/SLimited assurance conclusionWe have conducted a limited assurance engagement on the sustainability statement of NTG Nordic Transport Group A/S (the âGroupâ) included in the Management review (the âSustainability Statementâ), pages 42â101, 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 paragraph 99 a, including: · compliance with the European Sustainability Reporting Standards (ESRS),including that the process carried out by the management to identify the information reported in the Sustainability Statement (the âProcessâ) is in accordance with the description set out in the section âProcesses to identify and assess material IROâsâ, page 54; and· compliance of the disclosures in the section âEU Taxonomyâ of the Sustainability Statement, pages 70-75, with Article 8 of EU Regulation 2020/852 (the âTaxonomy Regulationâ).Basis for conclusion We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information (âISAE 3000 (Revised)â) and the additional requirements applicable in Denmark. The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our responsibilities under this standard are further described in the Auditorâs responsibilities for the assurance engagement section of our report. Our independence and quality managementWe are independent of the Group in accordance with the International Ethics Standards Board for 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.Our firm applies International Standard on Quality Management 1, which requires the firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.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 included in the section âProcesses to identify and assess material IROâsâ. 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, which includes the information identified by the Process, in accordance with the Danish Financial Statements Act paragraph 99 a, including: · compliance with the ESRS;· preparing the disclosures as included in the section âEU Taxonomyâ 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. 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.Auditorâs responsibilities for the assurance engagementOur responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Process include:· Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; · Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and · Designing and performing procedures to evaluate whether the Process is consistent with the Groupâs description of its Process, as disclosed in the section âProcesses to identify and assess material IROâsâ.Our other responsibilities in respect of the Sustainability Statement include: · Identifying where material misstatements are likely to arise, whether due to fraud or error; and · Designing and performing procedures responsive to disclosures in the Sustainability Statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.Summary of the work performedA limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement. The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise, whether due to fraud or error, in the Sustainability Statement.In conducting our limited assurance engagement, with respect to the Process, we: · Obtained an understanding of the Process by performing inquiries to understand the sources of the information used by management; and reviewing the 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 the section âProcesses to identify and assess material IRO'sâ.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 the information identified by the Process is included in the Sustainability Statement;· Evaluated whether the structure and the presentation of the Sustainability Statement are in accordance with the ESRS;· Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability Statement;· Performed substantive assurance procedures on selected information in the Sustainability Statement;· Where applicable, compared disclosures in the Sustainability Statementwith the corresponding disclosures in the Financial Statements and the Management review;· Evaluated the methods, assumptions and data for developing estimates and forward-looking information; and· Obtained an understanding of the Groupâs process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Sustainability Statement.</arr:AuditorsReportOnSubstainabilityReport>
<arr:AddresseeOfAuditorsReportOnSubstainabilityReports contextRef="ctx-1" id="f0__s11__7__212" xml:lang="en">To the stakeholders of NTG Nordic Transport Group A/S</arr:AddresseeOfAuditorsReportOnSubstainabilityReports>
<arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport contextRef="ctx-1" id="f0__s11__7__213" xml:lang="en">Limited assurance conclusionWe have conducted a limited assurance engagement on the sustainability statement of NTG Nordic Transport Group A/S (the âGroupâ) included in the Management review (the âSustainability Statementâ), pages 42â101, for the financial year 1 January â 31 December 2025.</arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport>
<arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport contextRef="ctx-1" id="f0__s11__7__215" xml:lang="en">Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Danish Financial Statements Act paragraph 99 a, including: · compliance with the European Sustainability Reporting Standards (ESRS),including that the process carried out by the management to identify the information reported in the Sustainability Statement (the âProcessâ) is in accordance with the description set out in the section âProcesses to identify and assess material IROâsâ, page 54; and· compliance of the disclosures in the section âEU Taxonomyâ of the Sustainability Statement, pages 70-75, with Article 8 of EU Regulation 2020/852 (the âTaxonomy Regulationâ).</arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport>
<arr:StatementOfAuditorsResponsibilitySubstainabilityReport contextRef="ctx-1" id="f0__s11__7__214" xml:lang="en">Auditorâs responsibilities for the assurance engagementOur responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Process include:· Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; · Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and · Designing and performing procedures to evaluate whether the Process is consistent with the Groupâs description of its Process, as disclosed in the section âProcesses to identify and assess material IROâsâ.Our other responsibilities in respect of the Sustainability Statement include: · Identifying where material misstatements are likely to arise, whether due to fraud or error; and · Designing and performing procedures responsive to disclosures in the Sustainability Statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.</arr:StatementOfAuditorsResponsibilitySubstainabilityReport>
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<arr:SignatureOfSubstainabilityAuditorsDate contextRef="ctx-1" id="f0__s11__7__217">2026-03-04</arr:SignatureOfSubstainabilityAuditorsDate>
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<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-48" id="f0__s11__7__218" xml:lang="en">Tue Stensgård Sørensen</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx-48" id="f0__s11__7__219" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx-48" id="f0__s11__7__220">mne32200</cmn:fIdentificationNumberOfSubstainabilityAuditor>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-49" id="f0__s11__7__223" xml:lang="en">Jacob Brinc h</cmn:NameAndSurnameOfSubstainabilityAuditor>
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<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx-49" id="f0__s11__7__225">mne35447</cmn:fIdentificationNumberOfSubstainabilityAuditor>
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<gsd:InformationOnTypeOfSubmittedReport contextRef="ctx-1" id="f0__s1__72__15">Annual report</gsd:InformationOnTypeOfSubmittedReport>
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