e-Boks Communication on Progress ESG Report 2024

Page 1


2024 ESG report

UN Global Compact Communication on Progress

A letter from our CEO

In 2024, more than 24.1 million digital postbox accounts had been created through e-Boks. These digital postboxes enable citizens across the world to access, sign, and store critical documents from more than 30,000 public and private institutions – including banks, pension funds, insurance and utilities.

With our roots in Denmark, one of the world´s most digital democracies, e-Boks has spent the past 24 years helping build better digital societies. Today, our services support secure communication and digital infrastructure in countries such as Denmark, Greenland, Norway, Ireland and beyond.

Our successful expansion continuously draws from being at the frontline of Denmark’s digitization journey where e-Boks remains among the most trusted and used secure digital postboxes, covering 90 per cent of the Danish population, or 5.3 million users.

Citizens’ access to secure digital postboxes are foundational for securing their legal rights and identities and for the efficient and trusted communication between public authorities, citizens and businesses. As we continue to expand across sectors and nations, our growth is underpinned by key principles of social inclusion, accessibility, security, and safety of data. That is how we contribute to Sustainable Development Goal 16: Peace, Justice and Strong Institutions. At the same time, our growth is closely linked to the transition towards paper-free distribution of documents – reducing environmental impact and promoting more sustainable communication practices. In doing so, we also actively support SDG 13: Climate Action and 12 Sustainable Consumption and Production. Today, as a consultative committee member of the Universal Postal Union — the UN’s specialized agency for strengthening global postal systems — e-Boks contributes digital expertise to

shape the future of secure postal communication in a digital first world. In 2024, we published a joint Whitepaper – ”Digital Postbox - Redefining Communication Solutions for Modern Postal Challenges”. The Whitepaper looks at how postal services must become fit for the digital age and regain and reinforce their role as national infrastructure providers, indispensable as secure, single access, omnichannel platforms for digital communication that protect citizens, institutions, and businesses in the digital era.

As our societal role expands, so does our responsibility to ensure that our governance structures, ESG practices, and strategic priorities reflect the expectations of users, partners and regulators across markets. We remain committed to the Ten Principles of the UN Global Compact, and in 2024, we chose to raise the bar by aligning our reporting with the EU Voluntary Sustainability Reporting Standard for SMEs (VSME). By adopting this standard, we are not only increasing transparency but also strengthening our internal policies and setting more ambitious goals for our ESG performance.

Assessing our ESG risks and opportunities from a double-materiality perspective, a strategic focus for e-Boks remains to ensure regulatory, customer and end-user trust to our secure digital platform and services in an evolving threat landscape. Growing concerns among governments and private enterprises about the need for strengthening cyber security and data privacy measures has meant that our know-how and solutions are more sought after than ever. We welcome and support EU efforts of shared standard setting for a safer digital space for all EU citizens.

”Shared digital security and data privacy standards are our best protection in these difficult geopolitical times.”

From 2026, all EU countries must offer a digital identity wallet, enabling citizens and businesses to identify themselves securely and share credentials across borders. At e-Boks, we fully support this important step toward a more connected and digital Europe. With our long-standing role as a trusted platform for secure communication, e-Boks is now expanding into the digital wallet space. We’re building on our trusted foundation to help users verify their identity and manage digital credentials contributing to more secure and inclusive digital societies. Our new e-Wallet, developed in collaboration with award-winning startup dewa – founded by graduate students from Technical University of Denmark and Technical University of Munich –

allows users to store and share verified IDs and documents with full control over their own data. It’s a key milestone in our ambition to make digital identity seamless, secure, and privacy-first.

I would like to end by thanking our partners and our users for their continued trust and collaboration. I would also like to thank my e-Boks colleagues for their dedication and commitment to our shared cause of creating better digital societies. What makes e-Boks truly exceptional is the people who stand behind it.

Introduction

As a secure digital platform for communication, document delivery and storage of important documents, e-Boks delivers an important part of the societal infrastructure that makes modern society function and thrive.

e-Boks has been part of the UN Global Compact (UNGC) since 2018, and the 2024 sustainability report is the 7th time we are reporting on progress against the UNGC Ten Principles and the Sustainable Development Goals. Since 2021, we have reported in alignment with the Carbon Disclosure Project (CDP) and in 2023, we set a baseline for our CO2 emissions in Scope 1, 2 and 3. With this foundational work, we have signed up to the Science-Based Targets initiative (SBTi) in 2024, submitting our CO2 reduction targets for Scope 1 and 2.

In our 2024 report, we have raised our ambitions by adding an additional reporting layer. We now report in accordance with the EU’s Voluntary standard for SMEs – VSME. This approach provides our customers and suppliers with access to key ESG metrics aligned with the EU’s internationally comparable indicators.

About e-Boks

In 2001, e-Boks was launched to facilitate a secure and more effective way for companies to communicate with their customers and public authorities with citizens. Since then, e-Boks has played a pivotal role in digitalizing the infrastructure in Denmark and across the Nordics and beyond.

Today, e-Boks is a trusted provider of secure digital infrastructure, offering digital postboxes and document services, while also expanding into value-adding features such as payments, digital consent, and e-wallet functionality. e-Boks plays a critical role in the digital infrastructure of modern society. We offer companies and public authorities an effective, secure, and user-friendly platform for digital communication. As an official Danish “viewing client” for digital post from public authorities, e-Boks enables citizens to receive, store, and manage important and private messages and documents from both public institutions such as tax authorities, health services, and municipalities, and private companies including banks, insurance firms, and utilities.

According to the OECD11, Denmark remains among the best countries in the world to provide

digital public services and is no. 1 when it comes to user-driven digital services. Today, 90% of all Danish citizens, 5.3 million Danes, use the secure digital postbox provided by e-Boks, accessed with their personal secure digital ID.

e-Boks Group is an independent public limited company co-owned by Nets and PostNord, providing national digital post solutions to the governments of Denmark, Greenland, Norway, and Ireland. e-Boks operates across several B2B markets, including banking, insurance, pension, and telecommunications sectors, partnering with a wide range of companies to digitalize and streamline their communication processes. e-Boks has activities in 7 countries.

In 2023, e-Boks joined the Universal Postal Union Consultative Committee. This partnership underscores our commitment to the sustainable digitisation of global postal services. By leveraging our expertise in secure, encrypted digital platforms, we aim to enhance the efficient and eco-friendly distribution of digital post worldwide.

Purpose and mission

Reducing the environmental footprint of our public and private partners and their users It is e-Boks’ purpose to create better digital societies by:

Protecting and safe-guarding citizen’s rights

2024 in numbers

30,000 public and private institutions using e-Boks

90% of the Danish population using e-Boks

201 million DKK in net sales

24.1 million user accounts globally

100% GDPR and eIDAS compliant

7 countries using e-Boks

582 million documents sent

Our Business Model

Key Resources Core Activities

We finance our investments through cash flow from our operations, and through our public-private ownership structure of PostNord A/S and Nets Denmark A/S

We invest in digital solutions and applications, which can be used together with relevant systems and platforms across geographies and enterprises to scale up the secure and efficient communication between public authorities, citizens and businesses

We rely on external data centres to power our business. Data centres consume vast amounts of energy, and as an important digital player, we are committed to sourcing 100% carbon neutral data by 2030

We rely on a highly skilled workforce to operate our business, and we work to secure a pipeline of diverse talent from leading educational institutions

We rely on a culture of security and integrity that always puts citizens’ interests first – their right to privacy, confidentiality and secure transaction of their personal data

We rely on constructive collaboration with public and private partners to enable e-Boks to strengthen people’s legal rights, protect their fundamental freedoms, secure their legal identities and enable their secure and transparent access to public and private institutions. This is our commitment to SDG 16

Provides end-users with a lifelong personal and secure postbox for important and sensitive information from public authorities and private businesses. Secure identification of end-users is based on national eIDs

Secure Distribution

Guarantees a safe, digital distribution channel for sending sensitive and confidential personal data

Secure Dialogue Portal

Provides sender with the option to establish confidential, reliable, and secure two-way communication with end-user

The e-Boks portal solution for corporate online systems provides an integrated platform for digitizing costly and time-consuming manual processes into companies’ own digital universes. It supports the digital signing of documents, sending notifications, and the secure dialogue between sender and end-user

Signing

Offers sender and recipients a convenient, reliable and secure way of signing documents (agreements, contracts, offers) digitally from both PC, tablets and mobile phones, including notification service, follow-up service, and archiving options

e-Boks KYC Payment

Provides recipients a convenient and secure way of paying invoices. Processes the invoices in collaboration with existing payment service providers (PSP)

e-Boks Plus

e-Boks Plus is a self-service universe that is displayed in a separate section in the e-Boks app. Here e-Boks’ mobile app users in Denmark, Sweden and Norway can access value-added services provided by e-Boks and third parties

e-Boks has joined forces with MEO to solve the challenge of ineffective KYC processes. The platform is built to ensure the compliance of anti-money laundering and GDPR regulation. With the KYC solution companies can request the necessary identification in e-Boks, and the customer can upload documents securely in the same place

Digital Identity Wallet in 2025

With the European Union mandating all EU countries to provide a digital ID wallet by 2026, e-Boks now offers a secure European digital identity wallet developed by award-winning Danish start-up dewa. The digital e-Wallet makes it easy and secure to identify oneself, sign documents, and store personal credentials

How We Create Value for Society

• 24 years of experience as a provider of effective and user-friendly digital infrastructures

• Insights from public-private partnerships in 7 countries

• Co-creation with users

• 30,000 public and private institutions using e-Boks

• Data Centre providers committed to becoming carbon neutral by 2030

• Financial resources

• Diverse talent

Protecting and safeguarding citizen’s rights

Reducing CO2e emissions

• 582 million documents sent through the e-Boks platform

• We strive to source 100% carbon neutral data by 2030

We are committed to SDG 12

• 24.1 million user accounts with access to secure digital post

• 100% GDPR and eIDAS compliant

• 100% delivery guarantee of secure digital documents

Contributing to sustainable development through active participation in UNGC

We are a signatory to the UN Global Compact, and we are committed to the 2030 Agenda for Sustainable Development.

Through helping digitalize countries and companies, we aim to contribute to reducing the material footprint of paper and water per capita and per GDP.

Diverse talent amongst our employees

• 32.5% women

• 67.5% men

• 11 nationalities

Labour inspection report

e-Boks fulfils the requirements of the Danish Health and Safety at Work Act according to the latest expection by Danish Working Environment Authority – Arbejdstilsynet (2023).

Lower costs

Up to 80% savings on distribution costs by shifting from physical letters to digital documents.

Our Approach To ESG

With more than 24 years of experience in secure digital infrastructure and partnerships across seven countries, e-Boks creates long-term value through digital innovation, privacy-by-design, and societal engagement. We believe that digitalisati-

on should empower - not exclude - people. That is why we continuously improve accessibility, data security, and climate responsibility in how we design and deliver our services.

e-Boks’ Sustainability Journey: From Commitment to Action

Since 2018, e-Boks has continuously strengthened our sustainability profile by integrating international principles and aligning with globally recognised ESG frameworks.

e-Boks became a signatory to the UN Global Compact (UNGC) in 2018 and remains committed to integrating the Ten Principles related to Human Rights, Labour, Environment, and Anti-Corrupti-

on into our strategy, operations, and supply chain governance. These principles are embedded in our Code of Business Conduct, which is approved by the Board of Directors and Executive Management and extends to all collaborators, contractors, and suppliers. The timeline below highlights key milestones on our ESG journey:

Report in alignment with ESG-

Our Science Based climate targets were approved

Since our first Communication on Progress (COP) in 2019, we have reported annually on our progress, ensuring transparency and accountability.

In the years that followed, we advanced our ESG strategy with concrete actions:

• In 2021, we aligned our reporting with the Global Reporting Initiative (GRI) Standards and participated in the Carbon Disclosure Project (CDP).

• In 2022, we published our first standalone ESG report.

• In 2023, we established our baseline for greenhouse gas emissions and submitted our near-term climate target to the Science Based Targets initiative (SBTi).

• In 2024, our SBTi target was officially approved, reinforcing our climate commitment.

• In 2025, we aligned our 2024 report with the EU’s Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), applying both the basic and comprehensive modules with a focus on governance, policies, and targets.

Signatory to UN Global Compact
First CoP report
Joined the Carbon Disclousure project
Report in alignment with GRI
Joined the Science Based Targets initiative
Initiated Supplier governance efforts
stuctures
Report in alignment with VSME standard

Voluntary Sustainability Reporting Standard for non-listed Small- and Mediumsized Enterprises (VSME)

The European Union (EU) is setting a new common standard for developments of the ESG-reporting landscape with among others the development of a Voluntary Sustainability Reporting Standard for non-listed Small- and Medium sized Enterprises (VSME). The aim of this standard is to streamline and optimise the SMEs’ reporting efforts by incorporating the data requests of large undertakings. e-Boks supports the EU’s efforts and is applying the VSME standard for the first time in its 2024 report.

Better Data for Customers and Suppliers

By adopting the EU’s Voluntary Sustainability Reporting Standard for SMEs (VSME), e-Boks provides customers and suppliers with access to key ESG data aligned with EU-recommended indicators. This enhances comparability across countri-

es and industries and supports large customers— such as financial institutions—in streamlining their own sustainability reporting. By adopting the VSME standard, we are not only increasing transparency but also strengthening our internal policies and setting more ambitious goals for our ESG performance. By reporting under the VSME framework, e-Boks is both future-proofing its governance model and reinforcing its commitment to sustainable growth.

Looking ahead, we are implementing a structured approach to supplier governance, addressing ESG risks and due diligence in our value chain. Our journey up the maturity curve reflects e-Boks’ ambition to contribute actively to the green and digital transitions by improving transparency, accountability, and resilience across our operations and stakeholder relationships.

e-Boks Way of Doing Business:

We place human rights at the core of our business - above all else, it is essential that clients and users trust that e-Boks observes the following principles in the way we develop and manage our systems – integrity, availability, confidentiality, and privacy.

We strive to be a great place to work - our people policy and our Labour Code of Conduct set out to ensure that all e-Boks’ employees, as well as suppliers, no matter where they are in the world, are offered optimal and safe working conditions with respect for their private lives.

At e-Boks, we are in the business of protecting the environment by seeking to decrease our environmental footprint through collaboration with our suppliers, clients and users, as well as by looking at our own emissions. We include a broad range of aspects such as data warehousing to the offering of digital alternatives, and the physical mail distribution and storage of document

Stakeholder trust is our license to operate - trust is a prerequisite for our ability to maintain and grow our business. Our Code of Business Conduct describes how e-Boks strives to engage with our stakeholders with respect and in compliance with rules and regulations, while upholding high ethical standards in everything we do. Acting honestly, decently, and responsibly is a fundamental part of our values. We provide continuous training to our employees, endorse a speak-up culture, and provide means to report unethical behaviour in a safe and anonymous way.

Double Materiality and Stakeholder Engagement

Double materiality means taking an inside-out perspective in the way a company’s actions may impact people and planet, as well as an outside-in perspective in the way sustainability and climate may impact a company’s operations and finances. It builds the foundation for a company’s sustainability strategy decisions and reporting efforts. In 2024, e-Boks conducted an initial double mate-

riality assessment to identify ESG topics that are most material to e-Boks business and stakeholders. The stakeholder map below illustrates our identification of some internal and external factors that can impact – or might be impacted by –e-Boks’ operations and value creation. Our double materiality assessment and stakeholder map has been informed by the DI Digital ESG-kit.

SOCIETAL CRISIS

EXTERNAL STAKEHOLDERS

CLOSE STAKEHOLDERS

Stakeholder Engagement Overview and Structured Engagement

At e-Boks, stakeholder engagement is essential to ensure that our solutions remain relevant, inclusive, and trusted. We maintain structured and ongoing dialogue with a broad range of stakeholders—from employees and clients to regulators, NGOs, and civil society.

Stakeholder Focus Areas

Employees

Current and Future Talent

Employee safety, physical and mental health and wellbeing, inclusion, engagement, labour rights, and people development

Employee retention, attraction, and reputation among IT professionals.

Regulators

Policy Makers

Industry Associations

Compliance with existing and emerging digital and data-related regulatory frameworks (Danish and International)

Alignment with the EU’s Digital Decade strategy and national priorities for digital public infrastructure (Danish and International)

Sector-wide expectations for ethical, secure, and sustainable digital solutions

Public and private clients

Suppliers

Expectations regarding ESG performance and risk management across digital platforms, including financial institutions, utilities, private companies, and public institutions

Due diligence, ESG risks, transparency, and collaboration across the supply chain – key ESG partners include data centres, software providers and other critical providers

Owners Ensure shareholder value

Users and Citizens Security, accessibility, relevance, user-friendliness, and inclusion of e-Boks solutions

Structured Engagement

Ongoing employee–manager dialogues; eYou employee wellbeing pulse with direct manager; quarterly anonymously well-being employee survey, safe and healthy worksplace assessments (APV) every other year; external Whistleblower function

Engagement with higher education institutions; internal talent development initiatives

Ongoing dialogue with national and EU regulatory bodies; participation in public consultations and working groups

Monitoring of policy developments; on-going dialogues with authorities inside and outside the EU

CEO membership in the Danish ICT Policy Committee; participation in Copenhagen FinTech and the Data Ethics Forum (DI and Finansforbundet); consultative committee member of the Universal Postal Union

Annual ESG partner surveys; ESG requirements in tenders; ongoing dialogue on cyber security, privacy, and sector-specific ESG standards

Supplier assessments; identification of high-risk suppliers; intensified dialogue and alignment with ESG expectations

Annual ESG reporting process

e-Boks citizen panel; in-app feedback prompts; prototyping of new solutions; ongoing dialogue with NGOs representing elderly people and persons with disabilities; reporting of GDPR violations into the Danish Data Protection Agency; Voxmeter annual National Population Survey

e-Boks’ core operations are centred on development and data management. We collaborate with external data centres, to deliver secure and efficient infrastructure and document handling. With a lean organisational structure, our own resource and energy consumption is limited—and we continuously strive to reduce it further. As a result, our

Suppliers

Upstream

main environmental impact stems from the partners we engage with, the energy consumption of end-users, and the broader positive and negative impacts our services have on customers, endusers, and society.

Own Operations

Customers & End-users Infrastructure &

Downstream

e-Boks has identified the following key themes as material for e-Boks from an Impact-Risk-Opportunity (IRO) perspective in alignment with topics from the European Sustainability Reporting Standards (ESRS).

• Climate change: We enable our commercial partners, customers and users to reduce their emissions by transitioning from paper based to digital communication, while also reducing our own footprint

• Biodiversity: By reducing paper consumption, transport, and physical mail, we help lower pressure on natural resources and contribute indirectly to the protection of forests and ecosystems.

• Circular economy: In our own operation we support the reuse and recycling e.g. of IT equipment, contributing to lower waste and improved resource efficiency.

• Own workforce: As a highly specialised knowledge provider, our ability to attract, retain, and develop diverse talent with technological know-how and understanding of the needs of our customers and end-users, is essential to our innovative success, as well as fostering a work environment that support our employees’ well-being.

• Workers in the value chain: We have taken a risk-based approach to our supplier due-diligence process, including a Human- and Labour Rights perspective in accordance with the UNGC principles.

• Affected communities: We are committed to inclusive digital access and support the resilience of digital public services. We support the Copenhagen Pledge on Tech for Democracy as part of our commitment to ensure that digital technologies have a positive impact on democracy and human rights.

• Consumers and end-users: We serve millions of individuals and business owners and are directly responsible for secure, inclusive digital communication with privacy at the core of our service.

• Business conduct: Ethical governance, cybersecurity, and digital trust are central to maintaining our license to operate.

Impact, Risks and Opportunities for e-Boks

Material

topics Impact Risk Opportunity

Climate Change

Biodiversity and Ecosystems

e-Boks reduces the need for paper production, printing, and physical mail transport, thereby contributing to customers’ Scope 3 reductions and the broader green transition. e-Boks emits CO2 through its own operations, primarily from energy use in data processing and digital infrastructure.

By reducing paper use and physical mail transportation, e-Boks indirectly contributes to preserving forests and lowering pressure on natural ecosystems.

Exposure to stricter climate regulation, carbon pricing, and high client expectations for low-carbon digital services. Increasing demands for energy data, Scope 3 reporting, and climate targets are putting pressure on digital service providers to document their contributions.

Limited if any – biodiversity is not directly affected by core activities, but perception risk may arise in green procurement contexts.

Demand for climate-friendly IT solutions is growing. e-Boks enables clients to reduce emissions through digital communication. e-Boks can position itself as a low-emission digital communication solution that replaces the high-emission physical letters and transportation, and sets a target aligned with the SBTi.

Supports public and private clients’ biodiversity commitments through dematerialisation and responsible digital practices increases business opportunities.

Circular Economy

e-Boks reduces material waste by reducing the use of paper, printing, and physical transportation through digital communication solutions - both for clients, and within our own operations, e.g. by recycling IT equipment.

Own Workforce

Workers in the Value Chain

Affected Communities

e-Boks influences employee wellbeing, safety, diversity, and skills development in its direct workforce.

Working conditions with e-Boks key suppliers are part of e-Boks’ extended responsibility.

e-Boks provides critical digital infrastructure and plays a key role in ensuring secure digital access to essential public and private communication and services. However, as digitalisation accelerates, there is a risk that certain groups—such as older citizens or people with certain disabilities—may become marginalised if they lack the necessary digital skills or support to engage with digital solutions.

Failure to manage e-waste responsibly could lead to compliance issues, particularly in light of the EU Circular Economy Action Plan and the Waste Electrical and Electronic Equipment (WEEE) Directive, as well as increasing expectations for circular practices in Danish public procurement frameworks within the digital sector.

Talent recruitment and retention challenges – particularly in IT – may hinder innovation and growth.

Lack of documentation on labour practices may lead to exclusion from contracts or criticism from investors and authorities.

Cyber threats and GDPR breaches threaten data privacy, undermines public trust in secure digital platforms, and can cost millions of euros for a business. Digital exclusion of older people and vulnerable groups may impact social cohesion and public trust. This could threaten e-Boks license to operate and, worst case, the loss of trust in using e-Boks as a secure digital platform among public and private clients and end-users.

Enhances resource efficiency and supports procurement preferences for circular digital solutions among potential new clients.

A strong people culture attracts diverse talent and contributes to resilience and competitiveness. Investing in people enhances employer branding in a competitive market.

A strong value chain governance approach demonstrates responsibility and alignment with OECD and EU due diligence expectations and strengthens e-Boks competitiveness.

By working ahead of the data privacy and cyber security compliance curve, and by using state-of-the art security technologies and practices, e-Boks strengthens its own and clients’ competitiveness and resilience. Promoting inclusive access and contributing to resilient digital public services strengthens e-Boks’ social license to operate.

End-users

e-Boks has a direct impact on data protection, digital inclusion, and secure access to essential services for millions of users, who use e-Boks to access essential information. User experience and inclusion have significant societal implications.

Business Conduct Security, ethics, and transparency are directly linked to public trust and the functioning of a digital democracy.

Poor accessibility, low usability, or digital exclusion could lead to reputational damage and complaints.

Non-compliance or unethical behaviour could lead to fines, legal action, and loss of stakeholder trust and clients and erosion of brand value.

A user-friendly, inclusive, and secure platform strengthens both e-Boks and our customers’ relationships with end-users. By ensuring privacy, accessibility, and trust, e-Boks can attract more users and public-private partnerships. By listening to user-experiences and co-creating new solutions, e-Boks can maintain its relevance as a future-fit and value-adding secure digital platform, service and solutions provider.

A strong ethical foundation and high standards of data security and independent remediating action enhance e-Boks’ brand and enable access to public and financial sector partnerships. Strong governance builds resilience, supports expansion in regulated markets, and strengthens partnerships with public and private actors give assess to new markets.

The most Material Topics for e-Boks

Based on our internal 2024 double materiality assessment and IRO analysis, we have identified the following as our most material topics:

• Business conduct, climate change, own workforce, workers in the value chain, affected communities, and consumers and end-users.

• Circular economy—and, increasingly, biodiversity—are also expected to grow in significance over time.

As a trusted provider to major financial institutions, large private enterprises subject to enhanced sustainability reporting requirements, and the public sector, e-Boks recognises that strong sustainability performance is increasingly essential. This applies not only within our own operations but also across our supply chain and in relation to public procurement, where sustainability criteria are gaining weight as a decisive factor in tenders and partnerships.

ESG Governance Model

The tables below provide an overview of how material topics are linked to our external commitments and governance structures. The management board oversees implementation.

Enviormental

Climate Change

SBTi commitment, Climate risk integrated in ISMS (ISO 27001)

Biodiversity

Commitment to SDG 12 & 13; UN Global Compact

Data centre policy and supplier selection criteria

GHG tracking; External validation by Hansen & Ersball Agenda

Circular Economy

Workforce

Global Compact, D&I Statement

Labour Code of Conduct; D&I Statement; Whistleblower policy and system; Employees handbook

in

Global Compact; Digital Inclusion Commitment

Supplier Code of Conduct (e.g., restriction against any form of forced or involuntary labour, child labour), Procurement Policy

e-Boks Code of Business Conduct; e-Boks Labour Code of Conduct; Speak up system

eYou employee wellbeing pulse with direct manager, quarterly anonymously well-being employee survey, safe and healthy worksplace assessments (APV) every other year

Targets set 1.5°C 2030 reduction of Scope 1 and 2: 42% by 2030. Data centres 100% CO₂ neutral by 2030

Every year we will plant 10,000 trees through Trees for the Future.org resulting in 120,000,000 trees planted by 2030. 1.5 billion documents sent through our platform by 2030

Global Compact; Digital Inclusion Commitment

User Experience Guidelines; Privacy Policy; e-Boks Code of Business Conduct; Speak up system

Stakeholder dialogue with NGOs; user-centred service design; accessibility audits

User panels; in-app feedback; dialogue with civil society; co-creation workshops; User Experience Guidelines; Privacy Policy; Voxmeter annual National Population Survey

All key suppliers to adhere to CoC by 2025

NPS of 30

e-Boks Code of Business Conduct; e-Boks Labour Code of Conduct; Speak-up system

Security and Data Privacy Policy, Digital trust architecture,

Information

sight

95% staff trained in policy; few incidents reported to DPA (Datatilsynet)

Our Environmental Responsibility:

Advancing on Targets

As a digital platform and solutions provider, e-Boks’ greatest contribution to fight climate change and build a greener world is to enable the transition towards better digital societies. Every single action counts to deliver on the call for science-based climate action. That is why we at e-Boks have ramped up our efforts to deliver a transparent and insightful account of our CO2e emissions in accordance with the Greenhouse Gas (GHG) Protocol, and we have committed to emissions reduction targets through the Science-Based Targets initiative (SBTi).

We have worked systematically with our CO2e emissions since 2021 and have in accordance calculated our footprint for scope 1, 2 and material scope 3 categories. 2023 is the baseline year for our progress moving forward. All calculations for Scope 1, 2 and 3 have been validated by Hansen & Ersbøll Agenda, a third-party expert.

Progress on our Science-based Targets

Our SBTi targets were approved in Q1 2024, and it follows the streamlined validation route for SMEs with a commitment to reduce scope 1 and scope 2 GHG emissions by 42% by 2030 from a 2023 base year, and to measure and reduce its scope 3 emissions. This is classified as a near-term target

and is in line with the Paris Agreement. e-Boks will report on its progress each year, which can also be viewed on the SBTi Target Dashboard.

To reach our near-term target, e-Boks measures our CO2e emissions and accordingly implement actions to reduce impact. In 2024, e-Boks has taken a significant steps converting our fleet of company vehicles to 100% electric. Consequently, e-Boks’ Scope 1 CO2e emissions were reduced by 28.6% in 2024 compared to the 2023 base year, and a total Scope 1 and Scope 2 CO2e emissions reduction of 8.8%. The reduction is expected to be even higher in 2025, as the fleet vehicles were converted to electric in H2.

Climate Change Risks

As a digital platform, e-Boks is considering climate change risks associated with its Information Security Management System (ISMS). This consideration is a part of an Amendment 1 to ISO 27001, which e-Boks has implemented. In accordance, e-Boks is updating our Information Security and Data Privacy Policy with the new considerations of relevant ISMS climate risks. This update will be complete in 2025.

Our 2024 Climate impacts

Emission Profile and Distribution

In 2024, total Scope 1 and Scope 2 emissions (location-based) amounted to 30.84 tonnes CO₂e—a reduction from 33.80 tonnes in 2023 and 46.0 tonnes in 2022. e-Boks has set a target to reduce Scope 1 and 2 emissions to 19.20 tonnes CO₂e by 2030, equivalent to a 42% reduction from the 2023 base year.

However, the vast majority of our CO₂e emissions stem from Scope 3, which accounted for 475.14 tonnes in 2024 - representing over 93% of total emissions. Scope 3 emissions are primarily related to outsourced data processing, cloud infrastructure, and downstream digital document usage. The total CO₂e emissions for 2024 across all scopes were 505.98 tonnes, showing a continued reduction trend from 519.40 tonnes in 2023.

While transport and storage of digital data represent a fraction (1%) of the total CO2e emissions from producing, sending and storing digital letters, we recognize that data centres are still a major contributor to CO2e emissions.

According to the International Energy Agency, data centres worldwide are responsible for 1% of energy-related CO2e emissions. Since 2010, emissions have grown modestly, despite the rapidly growing demand for digital services. This is thanks to the energy efficiency improvement efforts and renewable energy purchases by companies in regions worldwide.

1% = digital transport and storage of data over the network

7% = energy used to produce the letter

23% = lifetime footprint of user’s computer

69% = lifetime footprint of sender’s computer

Nevertheless, emissions must halve by 2030 to get on track with the IEA’s Net Zero Emissions by 2025 Scenario. Our data centre provider, KMD, has set an ambition of becoming net-zero CO2 emissions from its own business activities (scope 1 and scope 2) by 2030 and achieve 100% renewable energy consumption by 2026. As we internationalize our business across the world, we have little direct impact on our custo-

Our Way Forward

e-Boks recognizes the need for setting absolute timebound corporate CO2e reduction targets, also in Scope 3. As a digital platform and solutions provider, however, we have limited control over the areas where our biggest CO2e emissions occur, upstream as well as downstream.

One crucial metric is the GHG emission intensity figure, which helps us measure the efficiency of our operations in terms of emissions generated based on number of digital documents. This number indicates that even though e-Boks’ total CO2e emissions increase as the number of digital documents also increase, the CO2e emissions pr unit of output are considered relatively low.

Our GHG emission intensity figure covers scope 1 and scope 2 emissions as these are the material emissions that e-Boks has the most control over. By employing this metric, we continue to drive sustainable progress and embed sustainability throughout our operations. Currently it does not

mers’ choice of data centre providers. However, we proactively demonstrate the full potential of transitioning to digital post, also advocating for choosing data centre providers that have committed to setting scienced-based targets towards the Paris Climate Agreement.

Another major scope 3 impact is from downstream Category 11: Use of sold products, which amounts to 30.37% of total CO2e emissions. For e-Boks this covers every time a standard digital letter of 1 MB is written and read on a computer using Wi-Fi, representing estimated 3.3 g CO2e per standard digital letter. In comparison, a physical letter of an equivalent size, produced and distributed in Denmark in 2021, was estimated to contribute to 28.7 g CO2e. This means that e-Boks has an overall positive downstream impact on CO2e, enabling the transition from physical to digital post. See also our case study on the following pages, which describes our historical impact in Denmark.

cover scope 3 emissions, as e-Boks has limited direct influence on these emissions.

Nonetheless, we strive to create a culture where we think green in the way we conduct ourselves on a day-to-day basis, including in the way we procure products and services, and by being an active stakeholder and sustainable partner with our suppliers and customers. We are continuously exploring ideas as to how we can contribute to lowering our direct company emissions in scope 1 and scope 2, but more importantly, also how we can be a catalyst for change in our supply chain and among our partners to lower our scope 3 emissions.

5.29 kg/ CO2e
Scope 1 + 2 carbon intensity figure in 2024
For every 1 million digital documents distributed

Case Study: e-Boks’ Contribution to the Danish Digital Transition and its Environmental Long-term Impact

Background

e-Boks has been a trusted provider of secure platforms and digtal postboxes for more than 24 years. With the establishment of a digital postbox in 2001, e-Boks was key in starting the digitalization of Denmark that today is placing the country among the top-three in the UN e-Government survey, and as the world’s most competitive digital economy by the IMD World Digital Competitiveness Ranking, among other things due to Denmark’s ability to shield personal data from cyber-attacks. Today, Denmark is ‘digital by default’ with 90% of the population having a secure digital postbox.

e-Boks’ Societal Impact over a Decade

It is e-Boks’ vision to create better digital societies and keep contributing to the sustainable development of society through digital transformation. The following model case description highlights how e-Boks, over the past decade, has contributed to a significant shift in the way private businesses and public authorities communicate and send letters in Denmark, and through that also has had a positive impact in reducing CO2e emissions and lowing the material footprint for the Danish population.

Model 1: e-Boks’ Contribution to Digital Transformation – a Summary

This model shows the historic development in e-Boks user accounts from 2013 to 2021 in a Danish context (silo diagram) combined with the historic development of digital documents available through the e-Boks platform compared to the total number of physical letters sent in Denmark1.

From 2013 to 2021, the e-Boks user base increased from 4 million to 6 million in Denmark. In the same period, the volume of digital letters grew to three times the number of physical letters – 542 million documents were available through our platform in 20212

The model shows how e-Boks over the past decade has contributed to a significant shift in the way people communicate and send letters in Denmark and how it over time has been possible to create a tipping point from physical letters to digital post (achieved in 2016).

Physical letters

28.7g/CO2e per letter

The CO2e emission per physical letters includes the emission from production (2.7g) of the paper and the distribution (26g) of the letters.

Digital documents

3.3g/CO2e per document

The CO2e emission per digital document distributed is based on the scope 3.11 emission data. Emissions have been calculated based on an average size of each digital letter of 1 MB and assuming that it is written and read on a computer using Wi-Fi.

1 The data for the physical letters sent in Denmark is derived from Trafikstyrelsens “Redegørelse for 2021 om det danske postmarkeds tilstand og udvikling”

2 The model shows the relation between letters sent based on numbers from the Danish postal service, PostNord and digital documents available through the e-Boks platform.

Model 2: e-Boks Contribution to Reducing the CO2e Footprint – a Summary

Emitted CO2-e for physical letters (PostNord) and digital post (e-Boks) in the period 2013-2021

Total CO2e emitted by 615M physical letters sent

Total CO2e emitted by 157M digital documents sent

Total CO2e emitted by 181M physical letters sent

Total CO2e emitted by 542M digital documents sent

Physical letters Digital documents

The model highlights how e-Boks is striving towards achieving its purpose and mission by reducing the environmental footprint of its services. The data highlighted in the model reveals that while the number of physical letters has decreased in the period, the number of digital documents has increased while still emitting less CO2e overall3. This is an important insight, as it indicates how a transition towards digital documents can considerably reduce the amount of CO2e emitted compared to conventional physical letters.

Model 2 tracks the development in physical letters and digital documents and shows the total emitted CO2e from each of these over a historic period from 2013 to 2021. The graph shows a positive trend in terms of climate impact, as the CO2e emissions from both the physical letters and digital documents has fallen over the period, reaching an all-time low in 2021. The graph shows that total CO2e emissions have fallen from approximately 28,900 tons to approximately 7,000 tons of CO2e emissions, this constitutes a 76% decrease in CO2e emissions or approximately 21,900 tons in total. This fall has

happened despite the amount of sent letters remaining the same. This is seen as in 2013 772 million letters were sent, whereas 723 million letters were sent in 2021.

The reason why CO2e emissions from digital documents first increases and subsequently decreases, is due to the relation between the changing CO2e emission factor and development in number of documents. From 2013 to 2015 e-Boks total number of documents distributed almost doubled, which was followed by a more steady growth in volume. Additionally, from 2014 to 2021 the calculated CO2e emission from digital documents fell from 35g/CO2e per document to 3.3g/CO2e per documents. The combination of these two factors has led to the graph’s trajectory.

3 The reduced CO2e emissions for physical letters are also attributed to PostNord’s own efforts to reduce CO2e emissions: https://www.postnord.com/ sustainability Last visited June 2025

4 See appendix B for a detailed elaboration

5 The emission number per digital document distributed is based on a French study conducted in 2022 by the researcher Basile Fighier: https://www.sami. eco/blog/empreinte-carbone-email Last visited June 2025

Our Social Responsibility:

Commitment to Human and Labour Rights and Societal Responsibility

At e-Boks we have a deep understanding of our role in society. Our operations effect a wide range of stakeholders from our own employees to workers in our value chain, and to the broader society, including end-users and affected communities.

e-Boks’ mission is to create better digital societies. As a signatory to the UN Global Compact and a supporter of SDG 16: Peace, Justice and Strong Institutions, we place human rights at the core of our business, and through our commitment to secure digital access and our Code of Business Conduct, we emphasize that all our products and services are designed to support a resilient and inclusive digital infrastructure, while keeping our users’ needs, rights, and interests in

mind. In doing so, we help strengthen democratic access to essential information and reinforce trust between citizens, businesses, and public institutions.

We recognise our influence on:

• The well-being and development of our employees

• Workers in our supply chain, especially in higher-risk geographies, through clear expectations on human rights, labour conditions, and supplier assessments.

• And most significantly, the 24 million user accounts of e-Boks globally, whose access to secure, transparent, and reliable digital communication shapes their interaction with public and private services.

e-Boks’ Social Scopes

As illustrated in the figure Social Scopes (source: Hansen & Ersbøll Agenda), our ability to measure and manage impact varies across different stakeholder groups. It is easier to control our impact on our own workforce, than it is on workers in our value chain or on end-users and affected communities. However, the number of individuals in-

SOCIAL SCOPE 1

Own workforce

SOCIAL SCOPE 2

Workers in the value

chain

fluenced increases significantly in Social Scope 3, where our digital infrastructure reaches 24 million user accounts globally. This reinforces the importance of responsible product design, accessibility, and long-term societal trust and dialogue with stakeholders, especially in our role as a provider of critical digital services.

SOCIAL SCOPE 3

Affected

communities, consumers and end-users

The further out in scope, the more difficult it is to measure and control impact.

SOCIAL SCOPE 1

Our Employees

- Attracting, Retaining, and Developing Digital Talent

As a highly specialised knowledge provider, e-Boks’ ability to attract, retain, and develop digital talent is essential to our innovation and long-term success. At the same time the working conditions and possibilities for professional growth are very important for our employees. In 2024, e-Boks employed 83 people on permanent contracts, all based in Denmark.

Adapting the Workplace to a Changing World

As a highly specialised knowledge provider,

e-Boks’ ability to attract, retain, and develop digital talent is essential to our innovation and long-term success. At the same time the working conditions and possibilities for professional growth are very important for our employees.

We aim to make e-Boks a great place to work by fostering a responsible and inclusive workplace that supports employee well-being, professional growth, and equitable working conditions. Our success is reflected in our employee turnover rate

of 10.8% in 2024, which is well-below the turnover rate of IT companies in Denmark. We closely monitor this figure as part of our efforts to support retention and employee well-being. Talent recruitment remains a particular challenge in the IT-sector, where competition is high and labour shortages are increasing. To strengthen our talent pipeline, we have launched several initiatives. For example, we collaborate with higher education institutions on student projects. A recent partnership with two students from DTU resulted in launching our digital identity wallet – e-Wallet.

Training and Development

Learning and development are critical to long-term employee engagement and performance. However, training data for 2024 was not available. We acknowledge this as a gap and are working to strengthen our efforts to improve data collection.

Gender Diversity and Inclusion

e-Boks is committed to promoting gender equality and an inclusive culture. Among our employees, we have a wide age range and growing diversity in nationality and backgrounds. While gender diversity remains a challenge in a male-dominated IT-sector, we always encourage everyone to apply regardless of gender, age, ethnicity, religion or disability .

We are committed to equal opportunities in hiring, pay, and promotion. All employees are entitled to parental leave under Danish law.

Code of Conduct and Grievance Mechanisms

e-Boks has a formal Code of Business Conduct and a human rights policy in place for all employees. An independent grievance mechanism is available to report concerns confidentially, including through the Zoios feedback platform and workplace assessments.

Incident Reporting

Working under Danish employment law and regulations, there are no incidents of child labour, forced labour, or human trafficking within e-Boks. There were also no confirmed human rights incidents involving workers in the value chain or affected communities. One internal case related to discrimination was handled appropriately through internal channels.

Policies Supporting Social Responsibility:

• Human Rights Commitment

• Labour Rights Commitment

• Employee Handbook

• Information Security and Data Privacy Policy

• Health & Safety Workplace Assessment

• Zoios employee well-being Survey quarterly

• eYou / People Development Dialogues

Next Steps

We will continue to enhance our social responsibility practices by:

• Strengthening gender balance at all levels

• Improving training data collection and transparency

• Maintaining a zero-accident culture through proactive health and safety measures.

People care about each other here

* The workplace assessment was conducted in February 2024.

number of employees in 2024 83

89% of our employees care about other at work

nationalities represented amongst our employees in 2024

Workers in the Value Chain

e-Boks is committed to promoting responsible business conduct across its value chain in alignment with the UN Global Compact’s Ten Principles, including those related to human rights and labour standards. To support this commitment, e-Boks has adopted a Code of Business Conduct that sets clear expectations for ethical behaviour, working conditions, and respect for fundamental rights throughout our supply chain.

As part of its ongoing efforts to improve supply chain due diligence, e-Boks is also implementing a supplier assessment process that will evaluate

critical suppliers on criteria such as human rights risks, working conditions, and compliance with international standards. This is particularly relevant for suppliers operating in higher-risk geographies, such as our data processing partner in India. Here, e-Boks places special emphasis on ensuring that workers’ rights are respected and that adequate safeguards are in place.

These initiatives reflect e-Boks’ broader ESG commitment and its role in fostering fair, safe, and responsible working conditions beyond its own operations.

Global Reach and Resilience - Affected Communities and End-

In 2024, more than 24 million user accounts worldwide accessed an e-Boks-powered secure digital postbox to receive, sign, and store essential documents from over 30,000 public and private institutions - including banks, insurance and pension providers, and utility companies. This widespread adoption reflects our core purpose: to build better digital societies and strengthen individuals’ legal identity, enabling secure communication, and promoting transparent access to both public and private services.

The increasing frequency of global crises - from pandemics to geopolitical instability - has underscored the importance of robust, reliable digital infrastructures. These developments have reinforced e-Boks’ role in society, helping to ensure continuity, accessibility, and resilience even in times of uncertainty. As more aspects of daily life are becoming digitalized, the ability to safely access official documents, exercise legal rights, and engage with institutions digitally have become a

basic social necessity - particularly for vulnerable or underserved communities.

Ensuring digital inclusion, privacy, and equal access to information are fundamental to our societal impact. e-Boks is designed to be secure, accessible, and user-friendly for all groups, regardless of digital literacy, age, or socioeconomic status. By maintaining high standards for data protection and universal accessibility, we aim to promote trust and bridge the digital divide.

In Denmark alone, over 90% of the population - equivalent to 5.3 million citizens - access the e-Boks platform using their secure digital ID. This underscores our role not only as a digital service provider, but also as a key enabler of democratic access, individual rights, and institutional trust.

e-Boks proactively collects and applies user feedback to improve the usability, security, and accessibility of its digital services.

e-Boks asked users how they prefer to communicate with public authorities and private companies. The results show:

• 88% find it attractive to be able to respond directly in e-Boks to a message from, for example, their municipality or insurance provider.

• 93% find it attractive to receive a reminder via SMS or email when they receive a new message in e-Boks.

• 95% find it attractive to be able to complete and return a form—such as a consent form—directly in e-Boks, rather than printing, filling out, scanning, and sending it back manually.

Source: e-Boks’ website

Case: Pension Providers Strengthen Engagement via

e-Boks

In 2024, several major pension providers—including PFA, PKA, AP Pension, Velliv, and others - moved their customer communications to e-Boks to improve engagement and reduce digital friction. This shift was driven by a key insight: traditional self-service platforms and email often fail to reach customers effectively.

A national survey by Voxmeter revealed that:

• Two-thirds of Danes prefer receiving pension information through e-Boks.

• One-third regularly delete emails without reading them.

• One in five Danes has mistakenly deleted a legitimate email as spam.

By using e-Boks, pension providers now benefit from:

• Significantly higher open and conversion rates (often over 90%)

• Greater customer trust and reduced phishing concerns

• Faster response times and improved document signing

For pension customers, this means more reliable access to critical information on coverage, contributions, and rights—delivered via a secure and familiar platform they already trust.

As e-Boks expand our activities in counties with less digital mature populations we develop new solutions to meet their need.

Source: e-Boks’ website

Our Governance Responsibility:

Trust, Security, and

Stability

At e-Boks, governance begins with trust. As a provider of critical digital infrastructure, we are entrusted with handling sensitive information for millions of citizens, public authorities, and private companies. Ensuring the reliability, stability, and security of our platforms is not just a technical priority — it is a fundamental obligation to society.

Global Reach and Resilience

Recent global crises, such as the COVID-19 outbreak, highlighted just how vital secure and efficient digital infrastructure is for maintaining societal continuity. These developments have further reinforced e-Boks’ role as a critical infrastructure

Our users must be confident that they can access their secure digital postbox at any time — and that their data is consistently protected, private, confidential and protected from external threats. This commitment lies at the heart of our governance framework and underpins all our systems, policies, and decisions.

provider, delivering digital services that are resilient, accessible, and secure — even in times of uncertainty. And the importance of being a trusted partner by public and private institutions.

Governance, Risk, and Information Security

As reflected in our Double Materiality Assessment, strong corporate governance, internal controls, and information security remain among the most material issues for e-Boks — both in terms of our societal impact and the financial operational risks - we must manage. In a time marked by growing geopolitical instability and increasingly sophisticated cyber threats, maintaining trust in the security, accessibility, and usability of our platform is more critical than ever.

As phishing attempts and cyber threats continue to rise, public trust in traditional emails and

text messages is steadily eroding. In this context, e-Boks is stepping forward as a trusted solution, offering secure digital post services that protect both senders and recipients from potential data breaches and brand-damaging cyberattacks. Growing scepticisms towards traditional emails and text messages underscores the demand for safer communication methods.

That is why e-Boks continuously strengthens its governance systems and safeguards the data and infrastructure - ensuring both resilience and regulatory compliance.

Corporate Governance and Ownership

e-Boks is an independent limited company (A/S) governed by Danish company law, co-owned by Nets and PostNord. The company is governed by a board of directors and an executive management team, who are jointly responsible for en-

suring compliance, ethical conduct, and strategic alignment with our ESG commitments. e-Boks maintains a clear division of responsibilities between board oversight and daily operations.

Gender Diversity at the Governance Level

e-Boks is committed to promoting diversity and inclusion at the governance level, recognising that a broader range of perspectives strengthens decision-making and accountability. As of the 2024 reporting year, e-Boks had a management board comprising 8 executives, of whom two were women and six were men. This corresponds to

Policies and Ethical Standards

e-Boks has implemented a robust set of policies and governance mechanisms to ensure ethical business conduct, data protection, and employee awareness. These policies are integral to our commitment to transparency, accountability, and the responsible handling of information.

a female-to-male management ratio of 0.33, up from 0.25 in 2020. A balanced representation in leadership – both from a perspective of nationality, gender, age and background - remains part of our broader ESG commitment and alignment with good corporate governance practices.

Key Policies and Governance Instruments:

• Code of Business Conduct

• Labour Code of Conduct

• Privacy Policy

• Whistleblower Policy

• Information Security Framework (ISO/IEC 27001 compliant)

• Employee Nano Learning Programme on Security and Ethics

Code of Business Conduct

Employees as well as business partners and suppliers comply to the e-Boks Code of Business Conduct

The Code of Business Conduct covers:

Legal compliance and human rights

Environment

Labour standards

incl. freedom of association, forced labour, child labour, non-discrimination and employment conditions

Non-compliance and corrective action

Health and safety

Confidential information

Anti-corruption

incl. prohibited business practice incl. gifts, hospitality and expenses, money laundering, and breach of competition laws

Labour Code of Conduct and Speak-Up Culture

In 2022, e-Boks introduced a dedicated Labour Code of Conduct to clearly articulate our expectations in relation to human and labour rights — especially as we expand globally. The policy encourages an open “speak-up culture”, where employees are supported in raising concerns and dilemmas related to ethical conduct or potential violations of our labour standards.

e-Boks monitoring of governance are all in green, as shown in the table on the right.

100% of our employees know and understand our Information Security Policy

We have a high level of security, ratedby PwC

100% of our employees know and understand e-Boks of Business conduct

Through our supplier contracts, all significant suppliers agree to adhere to e-Boks Code of Business Conduct

Green Green Green
Green Green Green
Green Green Green Green
Green Green Green Green

Privacy and Ethical Conduct

All employees at e-Boks are required to adhere to our Code of Business Conduct, which sets out clear expectations for responsible behaviour. Compliance is monitored through internal processes in our Security and HR functions. Immediate corrective action is taken in case of non-compliance. e-Boks does not tolerate violations of its Code of Business Conduct — whether due to deliberate actions, complacency, indifference, or poor judgement. An independent Whistleblower function allows for remediation without retaliation. In the event of non-compliance, we take prompt remedial action and implement preventive measures to avoid recurrence.

IT Security Governance

The e-Boks security governance model and Information Security Management System (ISMS) is based on ISO 27001:2013, This international standard provides organisations across all sectors with guidance on establishing, implementing, maintaining, and continually improving an ISMS.

Our overarching Information Security and Data Privacy Policy addresses the critical importance of security and compliance with the EU General Data Protection Regulation (GDPR) and ISO 27701 in all aspects of the business. The Information Security

Supplier Governance

Contractor and supplier selection is subject to a procurement process, which includes a checklist that enables us to conduct due care and due diligence in a structured process that encompasses our e-Boks Code of Business Conduct and high security standards.

Among our key suppliers are data centres and cloud partners which are ISO 27001 certified. Our contract templates include our Code of Conduct. e-Boks prepares an annual audit and assurance schedule covering internal and external audits in relation to IT security compliance. In 2024, 10 sup-

and Data Privacy Policy also describes and supports the functional areas and their security work, which include roles, responsibility, and accountability for the security personnel and the Security Board representing all areas of the organisation.

The Security Board is accountable for security and compliance in e-Boks, which ensures that all decisions and solutions have security at its core by incorporating the Defence in Depth principle and Privacy by Design. The Information Security and Data Privacy Policy is part of our Employee Handbook and is mandatory reading for all employees. In addition, we provide mandatory education and awareness training on a regular basis. Among other things, we have introduced a nanolearning system, where all employees are kept up to date on topics such as digital privacy, security, and compliance. Training comprises regular quizzes and questionnaires from both the Security and Compliance team building on the concept of STAR – Stop, Think, Ask, React.

In 2024, 3 incidents concerning consumers or end-users were reported to the Danish Data Protection Agency (Datatilsynet), which is a lower number of incidents reported than in previous years.

pliers were covered ranked in categories of high, medium, and low risk. Data centres are categorized as high risk from an IT security perspective, and here we conduct annual audits, including data centre inspections, user attestations, and testing of effective security controls, while simultaneously following up on previous audits to ensure proper security measures are addressed.

PwC conducts assurance of e-Boks overall IT security and compliance, including third-party assurance of our data centre providers.

The 2024 PwC management letter stated that e-Boks has a high degree of IT security and controls in place with no exceptions noted in the way e-Boks demonstrates leadership commitment, plans, supports, operates, evaluates performance and makes continuous improvements in compliance with its ISO 27001:2013 information security management system.

New Supplier Assessment

In 2024 and 2025, e-Boks developed a supplier ESG-assessment process to strengthen our sustainability governance structures and learn how suppliers implement sustainability practices in their business operations. e-Boks is continuously assessing and improving its own sustainability efforts, and this initiative represents a first step towards extending that assessment to its supply chain. Thus, e-Boks will send out a supplier assessment questionnaire (SAQ) to a selected group of suppliers based on an internal ESG-risk and -materiality screening.

The SAQ covers ESG topics and corresponding questions, drawn directly from the EU’s voluntary sustainability reporting standard, VSME. This standard is designed to ”provide information that will help satisfy the data needs of large underta-

Anti-Corruption

In 2024, no convictions or fines related to corruption were registered.

kings requesting sustainability information from their suppliers.” e-Boks has chosen to adopt this standard in support of, and alignment with, the EU’s guidelines for ESG data collection from the supply chain.

In addition, the SAQ includes topics relevant to value chain workers’ rights, based on materiality assessment recommendations from the Confederation of Danish Industry (DI) and the Ten Principles of the UN Global Compact. The information gathered will be used internally to establish an overview of each supplier’s sustainability maturity. This overview will help guide how e-Boks structures and prioritizes its future sustainability efforts within the supply chain.

The SAQ covers ESG topics and corresponding questions, drawn directly from the EU’s voluntary sustainability reporting standard, VSME. This standard is designed to ”provide information that will help satisfy the data needs of large undertakings requesting sustainability information from their suppliers.” e-Boks has chosen to adopt this standard in support of, and alignment with, the EU’s guidelines for ESG data collection from the supply chain.

ESG Dashboard

On the following pages, e-Boks’ 2024 ESG-data are presented. The data is aligned with the VSME disclosure requirements for the first time, and accordingly data has not been retrieved for disclosure requirements before 2024. The ESG-dashboard includes the disclosure requirements that were deemed material to e-Boks. A full dashboard is available upon request.

Governance

We have a high level of security, ratedby PwC

100% of our employees know and understand e-Boks Code of Business Conduct

Through our supplier contracts, all significant suppliers agree to adhere to e-Boks Code of Business Conduct

* Currently e-Boks only employs 2030 targets for selected ESG parameters. We are in the process of evaluating how we can best set targets, measure and track relevant KPI’s relating to our ESG activities, in order to ensure a high level of transparency in our reporting.

** The disclosure method for Scope 2 CO2 emissions has been updated, and thus location-based emissions have been seperated from market-based emissions, and only location-based emissions are included in the ESG Dashboard. This aligns with the accounting methods in the VSME-standard and the GHG Protocol. The update applies to all years to ensure comparibility.

*** The 2023 calculation has been performed following the GHG Protocol Corporate Accounting and Reporting Standard, and The Corporate Value Chain (scope 3) Accounting and Reporting Standard. The 2022-2023 variation in Scope 3 and overall can be explained as follows: The original calculation in Scope 3 was based on a life-cycle analysis which included relative CO2 emissions from the production of PCs, as a prerequisite for using e-Boks’ platform. Recognising that this calculation method involves a double counting of emissions, we have in 2023 only included Scope 3 category 11 – the direct consumption of electricity when using e-Boks’ platform – in actuality, scope 1 and 2 for the user – which is in accordance with the GHG protocol. This led to a significant reduction of e-Boks total CO2 impact from 2022 to 2023.

**** The reason why the ESG dashboard shows a drop from 744 to 546 million documents sent between 2021 and 2022, is due to a change in methodology. Previously all types of messages were included, where aswhereas now, e-Boks has decided to only count the documents which result in an invoice to a customer. We hope that this will give a more accurate depiction of the volume of digital documents distributed on the e-Boks platform. The 542 million documents mentioned in the historical model on page 10 corresponds to the 744 milionmillion documents in the ESG-dashboard for 2021 after the updated method has been applied.

Sources

Data centres CO2 emissions

Source: https://c2e2.unepccc.org/kms_object/global-growth-potential-of-energy-efficient-datacentres/

Data on paper production in Scandinavian context

Source: https://www.holmen.com/en/paper/sustainability/sustainability-stories/how-to-undrestandcarbon-footprints/

PostNord approach to sustainability

Source: https://www.postnord.com/sustainability

PostNord sustainability reports with data on distribution emissions

Source: https://www.postnord.com/da/investor-relations/regnskabsaflaggelse/arlige-rapporter-ogbaredygtighedsrapporter

Denmark remains among the best countries in the world to provide digital public services

Source: https://publicadministration.un.org/egovkb/en-us/Reports/UN-E-Government-Survey-2022 det%20danske%20postmarkeds%20tilstand%20og%20udvikling.pdf

French study with emissions for digital letters

Source: https://www.sami.eco/blog/empreinte-carbone-email

Number of letters sent in 2021 in Denmark

Source: https://www.trafikstyrelsen.dk/Media/638094774603594297/Redeg%C3%B8relse%20for%20 2021%20om%20

Third party ESG expert https://www.heagenda.dk

Appendix A

Model 1

Explainer: Note that the model illustrates a historical development in a Danish context and therefore does not necessarily reflect expected developments in other countries. Further, it cannot be assumed that emissions in other countries will follow the same development path, as this depends on several variables in each country, including energy composition and mix.

The model shows the relation between letters sent based on numbers from PostNord and digital documents available through the e-Boks platform. For the sake of transparency we want to highlight that documents available through our platform doesn’t equal read documents 1-to-1, as there are multiple digital solutions for Danish consumers. However, a survey conducted in 2022 shows that 90% prefer e-Boks to other digital sites. Therefore, we believe the numbers are still valid.

Sources:

Trafikstyrelsen: https://www.trafikstyrelsen.dk/Media/638094774603594297/Redeg%C3%B8relse%20 for%202021%20om%20det%20danske%20postmarkeds%20tilstand%20og%20udvikling.pdf

e-Boks: https://www.e-boks.com/danmark/da/nyheder/vi-goer-klar-til-ny-vaekst

Model 2

Explainer: The model displays a development that has been supported by e-Boks, but not necessarily driven by e-Boks. The reduced CO2e emissions for physical letters cannot be solely attributed to digitalisation in connection with e-Boks. The general technological development in Denmark, PostNord’s own initiatives, cultural behavioural changes, etc. also plays a role. The emission factors on which the figure is based are founded on certain methodological choices and estimates as described in appendix B.

Sources:

PostNord approach to sustainability: https://www.postnord.com/sustainability

PostNord sustainability reports with data on distribution emissions: https://www.postnord.com/da/ investor-relations/regnskabsaflaggelse/arlige-rapporter-og-baredygtighedsrapporter

Appendix B

Physical Letters

CO2e emissions from paper production and distribution of all physical letters sent via PostNord in Denmark in the period 2013-2021.

Production of Paper

It is important to note that the CO2e emissions related to paper production can vary significantly depending on the specific production processes and inputs used in the paper manufacturing. Factors to consider are the type of paper, the amount of reused paper fibres and the energy sources used etc. The emission factor associated with the production of paper includes CO2e emitted from the forestry management, raw materials, purchased energy, wood transportation, paper mills etc.

Distribution of Letters

The emission factors related to distributing letters in Denmark are based on publicly available data reported by PostNord. Data from 2014-2017 as well as 2021 is available and has therefore been interpolated to cover the remaining years of the model.

Source:

https://www.postnord.com/da/investor-relations/regnskabsaflaggelse/arlige-rapporter-ogbaredygtighedsrapporter

Digital Letters

CO2e emissions associated with the total volume of digital letters sent in Denmark via e-Boks in the period 2013-2021.

The emission factor of a digital letter depends on many different factors, e.g., the length of the message, the formatting, the addition of an illustrated signature, the weight of the attachments, the time it takes to write and read, the internet connection etc. The calculations of this model have therefore been developed based on several assumptions, such as the average size of all digital letters being 1 MB, and that all digital letters are written and read on a computer with Wi-Fi.

Carbon emissions associated with digital letters are broken down into 3 categories: Depreciation of the manufacture of the computers used to write and read the message, the energy consumption of the computer during the writing and reading of the email, and the transport of data over the network. Note that emissions associated with the storage of digital letters are excluded as e-Boks’ supplier of data hosting runs on renewable energy.

Two different emission factors have been applied, one from 2014 and one developed in 2021, for the calculation of carbon emissions related to sending digital letters through e-Boks’ platform in Denmark in the period 2013-2021.The first emission factor is based on data from the publicly available database, La Base Carbone, which refers to a report from 2014. The database is managed by the French Agency for Environmental Change (ADEME). The second emission factor is based on a French life cycle assessment (LCA) study from 2021 conducted on emails by a team of experts in measuring the carbon footprint of digital technologies.

Both emission factors cover the LCA of digital letters based on respectively 2014 and 2021 data. The two emission factors have been interpolated to cover the entire 2013-2021 period.

Source:

https://www.sami.eco/blog/empreinte-carbone-email

Turn static files into dynamic content formats.

Create a flipbook
Issuu converts static files into: digital portfolios, online yearbooks, online catalogs, digital photo albums and more. Sign up and create your flipbook.