Danske Bank A/S

###### ESG Integration Council

The ESG Integration Council comprises Heads of investment strategies
and was created to support ESG integration into the core of our investment
processes. Since ESG Inside® is about making better-informed investment
decisions, addressing risk issues, problems and dilemmas, and influencing
portfolio companies through active dialogue to contribute to a positive outcome,
decisions must be anchored in and supported by the investment organisation.

During the last 12 months, the ESG Integration Council has been involved in the
development and creation of new policies, instructions and initiatives related to
Sustainable Investments. This includes the development of voting guidelines,
Sustainable Investment Instructions, a commitment to Climate Action 100+ as
well as a new policy to restrict tobacco investments in order to meet customer
demands. [...] The Council is where I as CIO can take the lead in terms of ESG-related
matters. It is an important forum for me to strengthen and reinforce our view on
sustainable investments, i.e. organised bottom-up and anchored in our strategy
ESG Inside®. Moreover, this is the forum where the investment organisation
discusses and evaluates ESG risks and dilemmas, reviews and endorses
investment restrictions, decides on collaborative engagements, and decides
on other topics of relevance across my organisation.

The Climate Action Plan supports Danske Bank's Forward '28 corporate strategy, in which sustainability is one of four key strategic focus areas. Within our sustainability approach and priorities, we have identified three strategic focus areas: supporting our customers in their transitions, ensuring a robust and resilient bank, and managing our societal impacts. We govern the execution of the Climate Action Plan through our Executive Leadership Team and the Business Integrity Committee.

It is the responsibility of each manager to ensure that the Engagement Guidelines are known and complied with, where relevant within the employees' respective areas of responsibility. In addition, all employees need to understand and comply with relevant Policies and Directives, such as the Code of Conduct and Conflict of Interest Policy impacting our engagement activities. The exercise of Active Ownership is governed by the Group's Conflicts of Interest policy and instructions, through which actual and potential conflicts of interest are identified and recorded. [...] Collaborative engagements may also include contacting other investors to get support on engagement activities, and proposals tabled at general meetings. Decisions regarding collaborative engagement activities are taken by the Responsible Investment team, or if involving additional commitments by Danske Bank are lifted for decision with the Responsible Investment Committee. The Responsible Investment Committee is mandated authority to approve any new commitments that Danske Bank signs up for in respect to Responsible Investment (including engagement focussed commitments) and is also mandated to decide on engagement requests of material impact to the organisation. [...] All decisions related to exclusions are anchored within the investment organisation. As outlined in our Exclusion Instruction, all exclusions are first presented to the ESG Integration Council before being submitted to the Responsible Investment Committee for approval. [...] Engagement activities are registered and tracked through a centralised application, which is maintained by the Responsible Investment team. [...] The Responsible Investment team will, in cooperation with the relevant functions within Asset Management, annually review alignment with the approach outlined within the Engagement Guidelines. The conclusion of this evaluation shall be provided to the Responsible Investment Committee and the ESG Integration Council, as part of the annual update on Active Ownership activities and will inform the review of subsequent iterations of the Engagement Guidelines.

The Climate Action Plan supports Danske Bank's Forward '28 corporate strategy, in which sustainability is one of four key strategic focus areas. Within our sustainability approach and priorities, we have identified three strategic focus areas: supporting our customers in their transitions, ensuring a robust and resilient bank, and managing our societal impacts. We govern the execution of the Climate Action Plan through our Executive Leadership Team and the Business Integrity Committee.

The Responsible Investment Policy of Danske Bank adopted by the Board of Directors in December 2024 confirms and outlines our commitment to identify and prioritise principal adverse impacts on sustainability factors. The Responsible Investment Policy is subject to regular, not less than annual, reviews, with input from 2nd Line Risk Management, Compliance, the ESG Integration Council and other relevant stakeholders. The Responsible Investment Policy is approved with endorsement by the Responsible Investment Committee and Business Integrity Committee of Danske Bank A/S.

The responsibilities for the implementation of the Responsible Investment Policy are outlined in the policy, with the Responsible Investment Committee guiding its execution. The Responsible Investment Policy and its commitments to identify and prioritise principal adverse impacts are further operationalised through underlying instructions on Inclusions, Exclusion and Active Ownership with supporting guidelines. [...] Active ownership is the use of rights and position of ownership to influence the activities or behaviour of investee companies and other issuers. Danske Bank's approach to active ownership is governed through the Responsible Investment Policy as further operationalised through an Active Ownership Instruction.

The Active Ownership Instruction informs Danske Bank's approach to active ownership as a measure to protect the value of our customers' investments and to generate attractive returns, but also to be leveraged to manage the principal adverse impacts of investments we manage on behalf of our clients. Our approach is based on the belief that exercising Active Ownership in certain situations can facilitate the resolution of challenging issues more effectively than the imposition of exclusions and/or divesting, which could limit Danske Bank's opportunities as a responsible investor.

As further detailed in the Active Ownership Instruction, Danske Bank conducts active ownership through voting and engagement in which respect the principles of the Active Ownership Instruction are further guided through defined Voting and Engagement guidelines. Voting refers to the exercise of ownership rights at general meetings of companies where Danske Bank owns shares. Through voting, we seek to support a company's long-term growth potential, mitigate its sustainability risks and minimise companies' adverse impacts on society. We vote on management and/or shareholder resolutions to approve or disapprove of corporate governance practices as well as relevant environmental and social matters. We exercise voting by ourselves or by proxy through a third-party adviser. Our approach to using voting rights for the assets we have under management is outlined in our Voting Guidelines, covering a wide array of topics tied to the PAI-Indicators, including remuneration policies, capital structure and shareholders' rights, CO2 emissions, energy efficiency, gender diversity, biodiversity, human rights and anti-corruption. Voting is also conducted on proposals not specifically addressed by the Voting Guidelines, in which case our fiduciary duty to clients underpins our approach and evaluation of a proposal's likelihood of enhancing the long-term financial return or profitability of the company, or maximising long-term shareholder value. For actively managed funds, the voting rights are exercised in accordance with respective fund's objective and investment strategy. The investment teams have access to data, research and expertise, and voting decisions consider the sufficiency of information on matters. Engagement refers to the interactions that Danske Bank has as an investor with current or potential issuers (which may be companies, governments, agencies, municipalities, etc.). Engagements may be undertaken to influence (or identify the need to influence) sustainability practices and/or seek ESG information.

For engagement in relation to principal adverse impacts, Danske Bank seeks to engage with issuers where material environmental and/or social sustainability related issues have been identified. Our engagement activities may be constrained by pre-conditions, resources, and the type of asset class. The engagement applies differently depending on the asset class. Engagement is exercised by the Responsible Investment team and Investment teams in Danske Bank Asset Management. Also, engagements may be performed by asset managers to whom Danske Bank has sub-delegated investment management activities.

Danske Bank exercises individual engagement or in collaboration with other investors and organisations and is guided by our Engagement Guidelines. Individual engagement activities is organised across:

1. Thematic related engagements,

2. Event related engagements; and

3. Performance related engagements.

Thematic related engagements focus on selected systemic issues and adverse impacts that companies operating in certain sectors may be exposed to. The thematic engagements under the current version of the Engagement Guidelines relate to Biodiversity & Nature, Net Zero Commitments (Largest Emitters Focus), Net Zero Pathway Framework (Fossil Fuels Focus), and Human Rights, which are largely tied to PAI- Indicators 1(1)-1(4), 1(7) and 2(1)-(2). For these engagements we seek to encourage companies to minimize their adverse impacts within the selected scope and/or target setting. [...] On a multi-year basis, we select companies as part of our thematic engagement topics. Such companies are identified based on their exposure to the engagement topic, the size and relevance in terms of portfolio positions of investment teams and clients, and performance and risk related to the focus area. Screening for such companies is done in accordance with the process selected for each theme. Also, the selected themes are continuously reviewed and potentially revised or expanded.
Event related engagements are engagements which are initiated, when certain incidents or events occur. Event related engagements may be tied to any of the PAI-Indicators, where a significant negative operational performance and/or severe sustainability event has occurred. An event related engagement is generally prompted through findings done through the screening under Danske Bank's Sustainable Investment Model, where companies with significant negative performance in relation to the PAI-Indicators are identified. Furthermore, an engagement may be prompted through the screens conducted under our Enhanced Sustainability Standards screening. The Enhanced Sustainability Standards screening utilises the results from the controversies datasets that we receive from our ESG data vendors and supports the identification of certain companies/issuers engaged in certain activities and conduct deemed harmful to society.

Corporate issuers where Danske Bank has an ownership stake exceeding a value of 75 DKK mil or >0.40% ownership, are selected as engagement targets where highest controversies level has been issued from at least two of our ESG data providers and/or the company returns a "negative" or "very negative" operational performance result under our proprietary Sustainable Investment Model. Sovereign issuers are selected as engagement targets based on the lowest performing countries as per our country assessment model. The screening also includes inputs from the Responsible Investment Team and the outlook for any future engagement. The screens for issuers subject to our event related engagements are performed regularly and not less than on an annual basis and/or if otherwise prompted. Performance related engagements are engagements that are case-by-case dependent. The scope stems from the ongoing monitoring of issuers financial and non-financial performances, strategies, industry position, and sector trends. To support in the identification of sustainability issues that are most likely to affect an issuer's financial condition and operating performance, we leverage alongside access to sustainability research from ESG data vendors, and our own developed mSCORE (ESG Score). On a continuous basis, portfolio managers may select issuers for which engagement may improve the investment case or can mitigate investment risk related to governance and/or sustainability issues. Monitoring by investment teams identifies situations where there is a risk of loss of value or an opportunity to add long-term value through active ownership.

The approach to manage and address principal adverse impacts through engagement, is not systematically revised or escalated in situations where there is no reduction of the principal adverse impacts over more than one period. In the Active Ownership Instruction, the guiding principle for determining the best course of action for escalation is Danske Bank's duty to safeguard clients' interests. However, in such situations or if an engagement (either thematic, event or performance related) with a specific company is deemed unsuccessful, the relevant investment team or the Responsible Investment team may decide to escalate the engagement/the approach. By way of example, this could for a specific engagement be by using the outcome or progress of an engagement to inform the vote at the general meeting, hold/maintain weighting, decrease weighting, sell/divest the position and/or exclude or in certain situations conduct collaborative initiatives. Another supplementing measure to reduced impacts is integrated pre-trade warnings and pre- approvals tied to predefined thresholds for the PAI-indicators.

In respect to collective engagements, Danske Bank is a member of several investor organisations and investor initiatives, and we collaborate with a range of other relevant stakeholders. By doing this, we aim to contribute to the development of responsible investments and to promote transparency and sustainability standards in companies and in the financial markets. We work with other investors and stakeholders to exert active ownership and engage in joint dialogue with companies to contribute to positive change. By working together, we and the investment industry gain a stronger voice, and this enables us to put additional pressure on companies to address and improve on sustainability-related issues and have responsible business practices.

Find more information in our Active Ownership Instruction, Voting Guidelines and Engagement Guidelines on https://danskebank.com/sustainability-related-disclosures.

To ensure efficient execution and transparency within our climate efforts, we have implemented a governance structure consisting of five elements: [...] We have set out clear roles and responsibilities for approving, executing, and monitoring progress on our strategic direction, including our path towards net zero and our climate-related policies. Climate-related issues are anchored at the level of the Board of Directors (BoD) and the Executive Leadership Team (ELT).

The Responsible Investment Policy of Danske Bank adopted by the Board of Directors in December 2024 confirms and outlines our commitment to identify and prioritise principal adverse impacts on sustainability factors. The Responsible Investment Policy is subject to regular, not less than annual, reviews, with input from 2nd Line Risk Management, Compliance, the ESG Integration Council and other relevant stakeholders. The Responsible Investment Policy is approved with endorsement by the Responsible Investment Committee and Business Integrity Committee of Danske Bank A/S. [...] The responsibilities for the implementation of the Responsible Investment Policy are outlined in the policy, with the Responsible Investment Committee guiding its execution. The Responsible Investment Policy and its commitments to identify and prioritise principal adverse impacts are further operationalised through underlying instructions on Inclusions, Exclusion and Active Ownership with supporting guidelines. [...] Active ownership is the use of rights and position of ownership to influence the activities or behaviour of investee companies and other issuers. Danske Bank's approach to active ownership is governed through the Responsible Investment Policy as further operationalised through an Active Ownership Instruction. [...] The Active Ownership Instruction informs Danske Bank's approach to active ownership as a measure to protect the value of our customers' investments and to generate attractive returns, but also to be leveraged to manage the principal adverse impacts of investments we manage on behalf of our clients. Our approach is based on the belief that exercising Active Ownership in certain situations can facilitate the resolution of challenging issues more effectively than the imposition of exclusions and/or divesting, which could limit Danske Bank's opportunities as a responsible investor. [...] As further detailed in the Active Ownership Instruction, Danske Bank conducts active ownership through voting and engagement in which respect the principles of the Active Ownership Instruction are further guided through defined Voting and Engagement guidelines. [...] Voting refers to the exercise of ownership rights at general meetings of companies where Danske Bank owns shares. Through voting, we seek to support a company's long-term growth potential, mitigate its sustainability risks and minimise companies' adverse impacts on society. We vote on management and/or shareholder resolutions to approve or disapprove of corporate governance practices as well as relevant environmental and social matters. We exercise voting by ourselves or by proxy through a third-party adviser. Our approach to using voting rights for the assets we have under management is outlined in our Voting Guidelines, covering a wide array of topics tied to the PAI-Indicators, including remuneration policies, capital structure and shareholders' rights, CO2 emissions, energy efficiency, gender diversity, biodiversity, human rights and anti-corruption. [...] Engagement refers to the interactions that Danske Bank has as an investor with current or potential issuers (which may be companies, governments, agencies, municipalities, etc.). Engagements may be undertaken to influence (or identify the need to influence) sustainability practices and/or seek ESG information. [...] For engagement in relation to principal adverse impacts, Danske Bank seeks to engage with issuers where material environmental and/or social sustainability related issues have been identified. Our engagement activities may be constrained by pre-conditions, resources, and the type of asset class. The engagement applies differently depending on the asset class. Engagement is exercised by the Responsible Investment team and Investment teams in Danske Bank Asset Management. Also, engagements may be performed by asset managers to whom Danske Bank has sub-delegated investment management activities. [...] Danske Bank exercises individual engagement or in collaboration with other investors and organisations and is guided by our Engagement Guidelines. Individual engagement activities is organised across: 1. Thematic related engagements, 2. Event related engagements; and 3. Performance related engagements. [...] Thematic related engagements focus on selected systemic issues and adverse impacts that companies operating in certain sectors may be exposed to. The thematic engagements under the current version of the Engagement Guidelines relate to Biodiversity & Nature, Net Zero Commitments (Largest Emitters Focus), Net Zero Pathway Framework (Fossil Fuels Focus), and Human Rights, which are largely tied to PAI- Indicators 1(1)-1(4), 1(7) and 2(1)-(2). For these engagements we seek to encourage companies to minimize their adverse impacts within the selected scope and/or target setting. [...] Event related engagements are engagements which are initiated, when certain incidents or events occur. Event related engagements may be tied to any of the PAI-Indicators, where a significant negative operational performance and/or severe sustainability event has occurred. An event related engagement is generally prompted through findings done through the screening under Danske Bank's Sustainable Investment Model, where companies with significant negative performance in relation to the PAI-Indicators are identified. Furthermore, an engagement may be prompted through the screens conducted under our Enhanced Sustainability Standards screening. The Enhanced Sustainability Standards screening utilises the results from the controversies datasets that we receive from our ESG data vendors and supports the identification of certain companies/issuers engaged in certain activities and conduct deemed harmful to society. [...] Corporate issuers where Danske Bank has an ownership stake exceeding a value of 75 DKK mil or >0.40% ownership, are selected as engagement targets where highest controversies level has been issued from at least two of our ESG data providers and/or the company returns a "negative" or "very negative" operational performance result under our proprietary Sustainable Investment Model. Sovereign issuers are selected as engagement targets based on the lowest performing countries as per our country assessment model. The screening also includes inputs from the Responsible Investment Team and the outlook for any future engagement. The screens for issuers subject to our event related engagements are performed regularly and not less than on an annual basis and/or if otherwise prompted. [...] Performance related engagements are engagements that are case-by-case dependent. The scope stems from the ongoing monitoring of issuers financial and non-financial performances, strategies, industry position, and sector trends. To support in the identification of sustainability issues that are most likely to affect an issuer's financial condition and operating performance, we leverage alongside access to sustainability research from ESG data vendors, and our own developed mSCORE (ESG Score). On a continuous basis, portfolio managers may select issuers for which engagement may improve the investment case or can mitigate investment risk related to governance and/or sustainability issues. Monitoring by investment teams identifies situations where there is a risk of loss of value or an opportunity to add long-term value through active ownership. [...] The approach to manage and address principal adverse impacts through engagement, is not systematically revised or escalated in situations where there is no reduction of the principal adverse impacts over more than one period. In the Active Ownership Instruction, the guiding principle for determining the best course of action for escalation is Danske Bank's duty to safeguard clients' interests. However, in such situations or if an engagement (either thematic, event or performance related) with a specific company is deemed unsuccessful, the relevant investment team or the Responsible Investment team may decide to escalate the engagement/the approach. By way of example, this could for a specific engagement be by using the outcome or progress of an engagement to inform the vote at the general meeting, hold/maintain weighting, decrease weighting, sell/divest the position and/or exclude or in certain situations conduct collaborative initiatives. Another supplementing measure to reduced impacts is integrated pre-trade warnings and pre- approvals tied to predefined thresholds for the PAI-indicators. [...] In respect to collective engagements, Danske Bank is a member of several investor organisations and investor initiatives, and we collaborate with a range of other relevant stakeholders. By doing this, we aim to contribute to the development of responsible investments and to promote transparency and sustainability standards in companies and in the financial markets. We work with other investors and stakeholders to exert active ownership and engage in joint dialogue with companies to contribute to positive change. By working together, we and the investment industry gain a stronger voice, and this enables us to put additional pressure on companies to address and improve on sustainability-related issues and have responsible business practices.

We can monitor the progress of these companies through time and, if necessary, take corresponding action – including escalation, voting and as a last resort, eventual divestment. [...] Trade associations have a tremendous amount to bring to the table on climate matters, and can often be instrumental in moving policies forward. Through our engagement activities we encourage our investee companies to better disclose their memberships and to actively seek alignment of their climate policies with industry groups.

#### Governance of the Climate Action Plan

To govern the realisation of the targets and ambitions set out in our Climate Action Plan, we have put in place policies supplemented by position statements to guide our efforts. We have also established a governance structure with clearly defined roles and responsibilities, oversight from our Executive Leadership Team (ELT) and annual updates to the Board of Directors (BoD) to ensure execution and swift escalation in the event that material climate-related risks or issues arise.

Danske Bank Group policies and position statements guide us in achieving our ambition of supporting a Paris-aligned transition. For example, our updated Position Statement on Fossil Fuels stipulates that we will not offer long-term financing to any exploration and production oil and gas company that does not set a credible transition plan in line with the Paris Agreement. This requirement will help us drive society towards a more carbonefficient net-zero economy by 2050 or sooner.[20]

The responsibility for the execution of the Climate Action Plan is placed within our business units to ensure that actions on

The Board of Directors holds overall responsibility for the strategic direction of the Group; sustainability risks, including the Group's risk management of lending, are covered by the Board of Directors Risk Committee.

sustainability are embedded within our core business. Accordingly, sustainability has been fully integrated as a key pillar of our Forward '28 corporate strategy, launched in June 2023, and senior management remuneration is linked to progress achieved on our climate targets.

Our Group Risk Management and Group _Compliance functions are responsible for_ challenging our first-line execution. This challenge happens through these functions, both of which are represented in our Busi_ness Integrity Committee and Group All Risk_ _Committee, as described below._

Strategic execution oversight lies with our _Executive Leadership Team's Business_ _Integrity Committee, which is chaired by our_ CEO. The Business Integrity Committee is provided with quarterly updates on progress towards our climate targets and roadmapexecution updates. Centring our governance setup around the Business Integrity Com_mittee ensures senior management en-_ gagement in the realisation of the plan and anchors the executive power to steer and take action.

Our Group All Risk Committee receives execution updates on risk-mitigating actions relating to our Climate Action Plan. This is a

natural continuation of the second-line oversight of sustainability-related risks, which is specified in our Enterprise Risk Management _Framework._

**Figure 2.2: Governance overview**

ELT Committees Business Integrity Group All Risk Committee Committee

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Internal sustainability committees and internal position papers ensure alignment on key issues.

1) Executive Leadership Team sets Danske Bank's position and strategy on climate change and our sustainable finance policy.
By having our entire Executive Leadership Team, who often engage with policymakers on many issues and levels, represented in the Business Integrity Committee, our highest ranking committee for decision-making on sustainability issues, we make sure that Danske Bank's activities that influence policy are consistent with our position and strategy on climate change.

2) Sustainability and climate change as key focus for Public Affairs activities
Sustainability incl. climate change is a key focus of our strategy for Group Communications, which also includes Public Affairs. Moreover, activities relating to climate change are aligned through ongoing dialogue between our Group Sustainability unit and our Group Public Affairs unit.

3) Sustainable Finance Council includes Head of Public Affairs
Our Sustainable Finance Council serves a role to advise our Business Integrity Committee on issues relating to sustainable finance, which is a core part of our sustainability efforts and climate impact. The Sustainable Finance Council includes the Head of Group Public Affairs, thus ensuring alignment on this central area in relation to activities that influence public policy.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Ongoing internal alignment with relevant stakeholders, e.g., within Group Sustainability, to ensure consistency in all areas. Our focus is on EU regulation on sustainable finance following from the EU Commission's Sustainable Finance Action Plan and its subsequent Renewed Sustainable Finance Strategy.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes