GN develops, manufactures, and markets innovative hearing aids for people with hearing loss; headsets, speakerphones, and video equipment for collaboration at work; and a broad range of gaming gear. Our business model relies on customer-centric innovation, strong ecosystem and channel partnerships, agile and scalable operations, global reach, and engaged and competent employees as our key resources. We strive to maintain and further develop these key resources, providing benefits to our customers, investors, and other stakeholders.

There is no difference between specific markets, product categories, customers or end user when it comes to their relevance to our overall sustainability agenda, except for product safety, which only meets our materiality threshold for reporting for our hearing aids. In terms of geographies, some issues related to workers in our value chain are more relevant to specific regions.

We have identified one material negative, potential impact related to other work-related rights, covering child labor and forced labor, where we assess the potentially impacted workers to be either children working in non-certified mineral mines in the Democratic Republic of the Congo (DRC) and surrounding countries or bonded workers in regions with systemic forced labor. This potential impact also leads to a material potential financial risk, as non-compliance with forced labor legislation could potentially prohibit us from selling goods in certain markets, leading to a significant revenue loss.

The value chain includes raw material extraction such as mining, forestry, and fossil fuel extraction. However, there is no explicit mention of revenues or detailed involvement in coal, oil, and gas sectors.

The value chain includes processing of raw materials such as smelting, refining, petrochemicals, and paper milling. However, there is no explicit mention of chemicals production as defined under Division 20.2 of Annex I to Regulation (EC) No 1893/2006.

We are in continuous dialogue with our stakeholders to ensure we understand their requirements and find ways to work in partnership to strengthen our business and the societies in which we operate. This chapter covers who we consider our key stakeholders. Views of stakeholders related to sustainability are shared with Executive Management and the Board of Directors as part of overall sustainability governance.Customers: Customer-centricity is a key pillar of our strategy, which is why we continuously proactively engage with customers to understand their needs. Customer engagement takes place through direct dialogues, customer councils, and surveys. Views of customers are integrated into the development of our strategy and in the design of our products and services. ESG topics are integrated into customer dialogues, so that we can support customers in achieving their ESG objectives such as sustainable procurement or decarbonization targets. ESG is also integrated in customer dialogues as part of assessing potential upstream impacts and risks.Employees: To ensure the well-being of our employees and maintain a diverse, engaged, and passionate workforce, employee engagement takes place on an ongoing basis through several channels: biannual professional and personal development dialogues, employee surveys, and employee groups representing specific demographics and their allies. Employees are also represented in the Board of Directors through the employee-elected board members. Employees can raise concerns confidentially through GN’s whistleblower hotline or regular HR channels. Views of employees collected through these channels are integrated in strategy development, policy creations, adjustments, and other decision-making on a continuous basis. Where necessary, specific initiatives are developed to ensure employee well-being. Employees are informed about ESG topics regularly through internal communication channels, which also allow for engagement on topics communicated.Investors: It is GN’s investor relations and communication policy to have an open and active dialogue with our existing shareholders, potential shareholders, other investors, financial analysts, and the media. GN ensures that relevant information is provided to the financial community in a timely manner to ensure that the GN share is fairly priced. This is done in the form of company announcements, press releases, investor meetings, conferences, and presentations of GN’s interim and annual financial results.Following the release of interim and annual financial results, GN hosts roadshows where the Executive Management and the investor relations team inform shareholders, other investors, and financial analysts about the recent developments in GN.Moreover, when relevant, GN maintains a good dialogue with proxy advisors and other external advisors ahead of the Annual General Meeting.As a public company, GN discloses ESG data in relevant areas via our integrated annual report, our Annual General Meeting, and where relevant on request to ESG rating agencies and investors. To ensure our ESG disclosures always meet investor requirements, we welcome dialogue with our investors on ESG topics at any time. In 2024, we continued to make ESG a prominent part of our proactive communication with investors.Regulatory authorities: In support of our policy objective to proactively comply with all ESG legislation, GN assesses relevant regulations on an ongoing basis to ensure we comply with all relevant legislation, and where needed engage directly with policy makers to fully understand the implications of specific legislation for GN. We only engage policy makers on the shaping of future legislation through industry associations such as EHIMA, Danish Industry, and the Responsible Business Alliance, in line with their policy positions. New legislation is emerging in the area of product sustainability, including further chemical restrictions, right to repair, and battery legislation. On a corporate level, aside from CSRD, we closely monitor legislation in the area of ESG due diligence (CSDDDD) and human rights-related laws across many different geographies. Where necessary we adjust our strategy, product, and service offerings to comply with legislation.Suppliers: We engage with suppliers on an ongoing basis as part of regular business processes. We expect our suppliers to uphold the standards set out in our Supplier Code of Conduct and several supporting policies, employing a variety of tools to ensure compliance. Supplier ESG performance, based on their EcoVadis score and decarbonization maturity, is integrated into overall supplier performance and preference assessments. Where this is strategically relevant, we work in partnership with our suppliers to achieve joint business and ESG objectives.Industry and ESG associations: GN is a member of several industry and ESG-related associations, for the purpose of demonstrating commitment to jointly developed standards and policy positions, engaging with industry peers on industry-spanning issues, tracking legislation and engaging with policy makers through representatives of these organizations.

GN operates an asset light business model with a global value chain and is committed to consistently create value to all stakeholders.GN develops, manufactures, and markets innovative hearing aids for people with hearing loss; headsets, speakerphones, and video equipment for collaboration at work; and a broad range of gaming gear.Our business model relies on customer-centric innovation, strong ecosystem and channel partnerships, agile and scalable operations, global reach, and engaged and competent employees as our key resources. We strive to maintain and further develop these key resources, providing benefits to our customers, investors, and other stakeholders.There is no difference between specific markets, product categories, customers or end user when it comes to their relevance to our overall sustainability agenda, except for product safety, which only meets our materiality threshold for reporting for our hearing aids. In terms of geographies, some issues related to workers in our value chain are more relevant to specific regions.

As described in its charter, 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. Impacts cover areas where GN has a material impact on people or the environment, risks cover areas where ESG issues pose a material financial risk to GN, and opportunities cover areas where ESG issues present a material financial opportunity to GN. ESG is a quarterly recurring agenda topic in the Audit Committee. To ensure oversight of governance issues, business conduct cases reported through GN’s whistleblower hotline, as well as any other governance-related topic that requires Board oversight, are also presented to the Audit Committee on a quarterly basis.As part of the review and approval of GN’s double materiality assessment (see pages 49-51), in the reporting year, the Audit Committee was informed about all identified material IROs as part of approving their materiality, as well as the approach to implementation of due diligence, and results and effectiveness of policies, actions, metrics, and targets that form the basis of the reporting scope of this report. Aside from overseeing the identification of material IROs as part of compliance with reporting requirements, the Board also oversees the implementation of managing material IROs where these have an impact on the company strategy or relate to matters of risk and compliance.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.Unless a specific element of IRO management requires a separate project or program governance to drive progress, all decisions related to ESG are taken within the existing governance and decision-making bodies. This reflects that ESG is integrated into existing business processes where possible, rather than treating it as a separate topic. Accordingly, GN does not have a separate ESG or sustainability committee.The leaders of GN’s business divisions and functions of scale together with the CEO and the CFO constitute the Executive Leadership Team (ELT). The ELT is responsible for monitoring, managing, and overseeing the implementation of policies, actions, and targets related to effective management of IROs. Group Sustainability, reporting directly to the CFO, holds overall responsibility for supporting the business in IRO management, sustainability strategy development, and ESG reporting.To ensure required progress on an operational level, ESG is discussed on at least a quarterly basis in the management teams of all divisions and functions of scale.In terms of ESG-related target setting, long-term strategic targets such as climate targets, are developed by management with support from key functions and approved by the Board through existing decision-making mechanisms.Sustainability-related performance in incentive schemesAs stipulated in our Remuneration Policy and reported in our remuneration reports, annual ESG-related bonus objectives are discussed and approved by the Remuneration Committee, where the Remuneration Committee is tasked to ensure ESG bonus objectives are aligned with the management of the most material ESG issues as part of the Board of Directors’ wider oversight of ESG topics. Progress on these targets is continuously monitored by subject matter experts in the business and discussed quarterly in ELT meetings.For the year 2024, these objectives consisted of one overall objective related to reducing carbon emissions across all scopes versus 2023 in support of making progress towards our 2030 climate targets, and 10 key actions related to decarbonization in specific areas, increasing circularity, ESG-related supplier engagement, sustainability-related marketing and CSRD compliance.All members of the ELT have separate targets related to Diversity, Equity, and Inclusion (DEI), focusing on initiatives aimed to increase representation of women in Senior Leadership roles across GN (see page 92).Where this is required, these objectives are cascaded down into the monetary short-term incentive objectives on an operational level across relevant divisions and functions.ESG-related objectives for the CEO and CFO are approved annually by the Remuneration Committee. In the reporting year, 7.2% of the annual bonus was dependent on these objectives for the CEO and CFO with 12% of their annual bonus was linked to ESG, of which 50% was related to reduction of carbon emissions.Sustainability reporting risk management and internal controlsOur sustainability reporting is integrated into the annual reporting process, which has a well-established process for internal approval, controls, and external assurance. ESG data is subject to internal controlling through a dedicated ESG control function in our finance organization. As 2024 is the first year of CSRD reporting, the control environment is less mature than in financial reporting.