Our Environmental Policy, covering GN’s approach to all material environmental topics across our own operations and value chain, includes a section on resource inflows, stating that our commitment to reducing resource inflows by optimizing for efficient resource use in the design of our product and avoiding unnecessary production waste. Where this is technically and operationally feasible, we are committed to introducing recycled or renewable alternatives for materials used in our products. For biological or renewable materials, such as paper and cardboard used in our packaging, we strive to source these materials sustainably to ensure this does not lead to deforestation. The provenance of the materials we use is pivotal to the impact of our value chain, which is why we source materials with credible third-party certifications, such as FSC, ISCC Plus and Global Recycling Standard.

Our Environmental Policy also covers resource outflows, stating that we strive to minimize generation of waste from our business by including circularity principles, such as durability, repairability, recyclability and ease-of-disassembly, into the design of our products. The policy also states that in terms of management of products in-market or at end-of-life, we strive to recover or maintain value through services and partnerships that support reuse, refurbishment or recycling of products or components through enabling remanufacturing, refurbishment, repair, out-of-warranty takeback schemes and as-a-service leasing models.

This policy is approved by our Board of Directors, and Executive Management is accountable for implementation.

Our policy commitments also include ongoing work to ensure compliance with product recycling legislation, where we finance recycling infrastructure according to the EU WEEE directive in EU markets. In the U.S. states, where some of our products are covered by extended producer responsibility legislation, in 2024 we established partnerships to enable end-users to send their products in for recycling.

In addressing our material IROs related to resource use and circular economy, we have taken considerable steps both in terms of the sourcing of materials for our products and the end-of-life management to limit outflows and waste. The actions undertaken in 2024, including those planned over the coming reporting period(s), are aligned with the existing parameters of our financial planning and business model.

Resource inflows – materials We aim to achieve at least 50% of materials in our products to be recycled or bio-based, measured as part of the total weight of mechanical parts, which is supported by a number of our circularity targets (see E5-3 Targets related to resource use and circular economy). In 2024, we have achieved an overall use of 19.1% across our full product portfolio, and we are continuously investigating more sustainable materials and evaluating their potential to ensure we have a catalogue of materials made from recycled or renewable resources available for product development. Our focus has been on plastics, but we have commenced investigating alternatives to metals and fabrics as well.

Resource inflows – packaging A key action for GN is increasing the share of packaging that is FSC Mix certified. During 2024, we increased the share of cardboard and paper packaging that is FSC certified to 71%. New product packaging has also been designed to increase its recyclability and percentage content of recycled material.

Moreover, we are also taking actions to increase the share of recycled and sustainably sourced bio-based material across the full product portfolio (see E5-3 Targets related to resource use and circular economy, see pages 81-82). To take further action in this area in 2025, we have dedicated resources towards product development to include at least 50% of such materials as a percentage of the total weight of mechanical parts, as a requirement in all new programs in Enterprise and for all non-True Wireless (TWS) headsets and mice in Gaming. In Hearing, we will be taking an action to investigate recycled materials for end user cases, chargers, and wireless accessories. Moreover, as noted by our action in 2024 on packaging – we will continue the rollout of FSC-certified packaging across all products to ensure more sustainably sourced materials are used.

Over the next two years, we are also aiming to take actions related to testing and introducing recycled metals, while between now and 2030, we will also investigate the feasibility of implementing more sustainable materials used in electronic components, such as PCBs, speaker drivers and batteries, working closely with suppliers and engaging in partnerships to drive innovation in these areas.

Resource outflows – repairability An important area for GN is to pursue initiatives relating to circular designs of our products to limit resource outflows. During product development process, we engage with internal stakeholders involved in product development to set requirements for ease of repair, remanufacturing and disassembly, striving to optimize our design for circularity without compromising on product quality and durability. While this is an ongoing process, we have taken considerable steps in 2024 to assess 16 of our products on the internal repairability index (see page 85), where most of them are considered (highly) repairable accordingly.

While we are working towards ensuring that our products are as repairable as possible, another key action is to also extend our repair and remanufacturing initiatives. For in-warranty products, our repair center in Xiamen, China, repairs headsets, speakerphones, and video bars. In 2024, 99% of products returned for repair were repaired.

Returned hearing aids are remanufactured at our site in Malaysia and returned to the market as replacement devices. In 2024, we achieved a remanufacturing rate of 48% for returned hearing aids.

Over the next year, we aim to achieve better repairability of all our products, which is also supported by our resource outflows target (see E5-3 Targets related to resource use and circular economy, see pages 81-82). In 2024, we also commenced a wide-ranging repair strategy program to run until 2027 with the aim of full compliance with right-to-repair and sustainable battery legislation and maximizing the value of repair for end-users, business partners, and our business through setting additional requirements for designing for repair and developing a scalable model for enabling product repair.

GN’s Group Business Ethics & Compliance department collaborates with the entire organization to mitigate risks of non-compliance with anti-corruption laws and GN policies. The commitment to business ethics is anchored in GN’s Ethics Guide, which outlines the responsibilities and ethical standards expected of all employees and relevant business partners. Standards, policies, and training programs play a critical role in preventing potential misconduct across GN. Additionally, it outlines a decision-making process that supports the resolution of ethical issues and identifies GN departments who are available to help and advice. Case studies are provided to illustrate how ethical responsibilities and guidelines apply in everyday situations. Key content includes the GN Alertline, ethical decision-making, business conduct, employment practices, compliance with laws and regulations, conflict of interest, bribery, and third-party management.

The GN Ethics Guide is managed and updated by the Group Business Ethics & Compliance department and applies to all GN employees, including members of the Board of Directors. The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. The Policy explains key terminology related to anti-bribery and anti-corruption, among providing guidance on key processes to prevent and detect misconduct. Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis. GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. The Policy explains key terminology related to anti-bribery and anti-corruption, among providing guidance on key processes to prevent and detect misconduct. Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis. GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

The EU Whistleblower Directive has been incorporated into Danish law and GN has established a whistleblower hotline, the GN Alertline, and implemented a Non-Retaliation Policy that ensures the protection of whistleblowers. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN’s intranet. Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN’s designated investigation unit in compliance with the Danish whistleblower law.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions. The Policy defines the purpose, scope, ownership, and responsibilities related to the management of anti-corruption. GN has appointed Group Business Ethics & Compliance department as the designated whistleblower investigation unit, in compliance with Danish law. Oversight of these investigations lies with GN’s Audit Committee, which is updated quarterly on findings and recommendations on cases received through the GN Alertline.

All employees and consultants are required to complete the annual mandatory Ethics Guide e-learning. In-person training is also offered where needed. Additionally, all new employees are asked to read and acknowledge the GN Ethics Guide as part of their onboarding.