Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis.

GN’s Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It 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. Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis. 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.

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws.

The Board of Directors’ Audit Committee holds overall responsibility for overseeing the management of ESG-related impacts, risks, and opportunities (IROs), reporting into the Board for related decision-making.

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 worldwide. Our 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. Our 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.

For an overview of the composition and diversity of the members of GN’s administrative, management, and supervisory bodies, see pages 36-38. To ensure appropriate skills and expertise in sustainability, ESG is part of the Board’s annual self-evaluation process. Sustainability-related skills and expertise related to our material IROs are currently assessed to be sufficient across the Board, but if this changes, it will be included in Board training or as a requirement in the recruitment of new members.