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 GN Ethics Guide is aligned with generally accepted standards of ethical business conduct as well as applicable regulations. It is publicly available on GN’s website in ten different languages via www.gn.com/documents and for employees also via GN’s intranet. 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.

We have set a target on deviation response time, which we measure as the time taken to initiate corrective actions if we have three consecutive months of underperformance against our response time KPI. The ongoing target and baseline value was 20 days which was formally defined in 2024. The average response time was 16 days in 2024, which was within the target value.

To set this target, we utilized a combination of quantitative analysis (e.g., incident data trends, KPI metrics) and qualitative assessment (e.g., internal audits, stakeholder feedback). Cross-functional teams including Quality, Regulatory Affairs, Risk Management, and Product Development are involved in defining, monitoring, and refining our KPIs. Feedback from regulatory bodies and industry partners informs our approach, particularly for adjusting compliance timelines and addressing emerging risks.