EthicsLine is our whistleblower system and main mechanism for identifying, reporting, and investigating concerns, promptly, independently and objectively as defined in the EthicsLine Policy. It accommodates both internal and external stakeholders. It allows employees and business partners to report suspected violations of Vestas Codes of Conduct, applicable laws, and Vestas policies. Hosted on a secure external platform, it ensures anonymity and protection from repercussion.

EthicsLine is our whistleblower system and main mechanism for identifying, reporting, and investigating concerns, promptly, independently and objectively as defined in the EthicsLine Policy. It accommodates both internal and external stakeholders. It allows employees and business partners to report suspected violations of Vestas Codes of Conduct, applicable laws, and Vestas policies.

Our Global and Regional Compliance Programmes serve as our training policy for business conduct and relate to our impact on corruption and bribery (including anti-bribery). Our Global and Regional Compliance Programmes are updated annually. The scope of the programmes is global and regional in nature covering all of Vestas’ own workforce. The target audience is defined through a risk-based approach linked to the global compliance survey and EthicsLine cases. The current functions determined to be most at risk for bribery and corruption are office employees and service technicians due to the nature of their functions. The fundamental training is conducted as part of the onboarding process and based on the survey and EthicsLine cases. Additional training is performed on a yearly basis, covering areas relevant for Vestas.

The current functions determined to be most at risk for bribery and corruption are office employees and service technicians due to the nature of their functions.

The policy is subject to legal requirements under national law transposing Directive (EU) 2019/1937 or equivalent requirements with regard to the protection of whistleblowers.

During the year, governance bodies are informed about sustainability matters in the following way:

• The CFO gives an update on non-financial matters to the Audit Committee and the Board every quarter.
• The Vice President and Head of Sustainability reports to the Audit Committee on performance on selected metrics relevant to key targets in the Sustainability strategy on a quarterly basis.
• Updates on implementation of due diligence take place via Enterprise Risk Management and the review of persistent risks.
• Reviews of the effectiveness of policies are currently taking place distributed throughout the year.
• Targets are evaluated annually in connection with the policy review cycle, depending on relevance.

Before being presented to the Board, all sustainability topics go through a review by the Executive Management team.

Vestas' governance bodies consider impacts, risks, and opportunities supported by the structure of the Enterprise Risk Management (ERM) programme. The structure of the ERM Annual Wheel supports them in overseeing strategy, risk management, and trade-offs related to impacts, risks, and opportunities.

The features of the annual risk management and internal control systems are aligned with the annual integrated reporting process. Relevant information from the double materiality assessment and other operational areas feeds into the risk reviews and thereby also the annual information flow managed by the ERM, involving the Risk Committee, Executive Management Team, Audit Committee, and Board of Directors.

The scope of risk assessments for all relevant areas in terms of strategic, financial, operational, and compliance risks, including material sustainability topics such as climate change mitigation and adaptation, anti-corruption and bribery, working conditions, and human rights. In terms of risk prioritisation, they are aiming at enhancing methodologies for identifying, assessing, and managing risks. Our risk prioritisation methodology is based on an assessment of risk severity (based on likelihood and impact) and mitigation efficiency (evaluating the effectiveness of current mitigation actions). The final discussion of prioritisation related to persistent risks takes place in the Risk Committee. The long-term emerging risks and opportunities are further aligned with the overall strategy process.

During 2024, the Board and Audit Committee were updated on sustainability topics by the Vice President and Head of Sustainability, providing information on the CSRD in general, the scope of reporting, implications, and the governance structures supporting the oversight of material impacts, risks, and opportunities.

With regards to policy reviews, the Board and Audit Committee reviewed the Tax Policy, the DEIB Policy, as well as the Human Rights Policy. There was one annual update on the scope of metrics in 2024, which will be revisited in February 2025. Furthermore, the targets on GHG emission reductions were evaluated, as these need to be revisited every five years in line with SBTi requirements.

The timeline to the right shows when these topics were addressed by the Board and the Audit Committee during the year.

During 2024, Vestas has also started developing new internal controls that will help ensure completeness checks for the Sustainability statement, referring to qualitative and quantitative data points in line with the ESRS. This internal controls process facilitates the identification of the information to be disclosed in relation to material IROs.

In terms of operational management of risks in a third-party perspective, we are certified in line with international standards, including ISO 9001 for Quality, ISO 14001 for Environment, and ISO 45001 for Health and Safety.

During 2024, we have also started developing new internal controls that will help us do completeness checks for the Sustainability statement, referring to qualitative and quantitative data points in line with the ESRS. This internal controls process facilitates the identification of the information to be disclosed in relation to material IROs.

The remuneration of the Executive Management team is linked to the results of Vestas’ financial and sustainability performance, through incentives. The annual process for selecting KPIs and setting targets for the incentives is based on Vestas’ strategic direction, and the KPIs are approved by the Board in the second quarter of the annual meeting cycle. The process includes input from each business area and leads to consolidated strategic prioritisation from the Executive Management and the Board when deciding KPIs and targets. For the Executive Management team, 10 percent of the short-term incentive scheme is linked to climate-related KPIs in the form of the KPI 'GHG emissions avoided.' During the year, no short-term incentives were paid to the Executive Management team linked to climate-related targets as the said targets were not met. The long-term incentives are not linked to sustainable targets, nor is the base remuneration. For the Board, 0 percent of the remuneration is linked to climate-related considerations.