In 2023, we commenced our double materiality process, in accordance with the process set out in ESRS 1, which covers general requirements for reporting in accordance with CSRD. We mapped our value chain and identified the industries on which we depend across our value chain.

Next, we identified impacts, risks, and opportunities (IROs) across our full value chain for all ESG sub-topics and sub-sub-topics contained in Appendix A of ESRS 1. To assess the materiality of different IROs and topics, we developed a scoring key from 0-5 for both impact and risk materiality and set a materiality threshold at 2 or above for materiality and 3 or above for highly material topics, where 2 represented low scale, concentrated scope, remediable with some effort and a low likelihood, while a 3 represented medium across the same variables. Through this process we assessed 31% of topics to be highly material and 21% of topics to be material for our own operations, and 45% of topics to be highly material and 35% of topics to be materials for our value chain.

In 2024, we finalized our double materiality process through the following steps:

• We made updates to IROs and scoring based on further inputs from stakeholders and additional guidance from EFRAG
• We set the reporting threshold at 3 or higher to focus reporting on the most material topics

We then mapped disclosure requirements and data points against material IROs to determine the contents of this Sustainability Statement, taking into account the specificity of IROs where needed to scope out data points where the IROs are limited to for example specific parts of our value chain, employee groups, or geographies.

We applied three analytical approaches in our double materiality process:

• Desk research: we consulted 40 reports from NGOs, governments, and key suppliers
• Internal workshops: we held five internal workshops with 27 subject matter experts
• External stakeholder interviews: we interviewed eight external stakeholders, constituting both readers of the report and impacted stakeholders. We selected external stakeholders based on the areas where we lacked visibility through our existing stakeholder engagement mechanisms: pollution, resource outflows, and human rights impacts far down our supply chain

We assumed our impacts and risks to be similar to industry averages in cases where we lacked clear data or were unable to allocate impacts prevalent to GN in our value chain.

Our double materiality assessment was subject to ongoing review by senior management. It was formally approved by the Audit Committee in August 2024.

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.