Social

S4Consumers and End-Users

5 disclosure requirements

S4-1

Policies related to consumers and end-users

7 companies
Modern Times Group MTGUnknown

Age classification of games

Games developed by MTG's companies are classified by either the International Age Rating Coalition (IARC) or the age rating systems on platforms such as Google Play and the Apple App Store. However, country or region-specific age limits may vary depending on the markets where the games are published.

Protecting minors' data

All MTG's companies continuously improve their data protection processes in accordance with the framework developed and governed by our Head of Data Protection. Tailoring these processes to individual games, their respective mechanics, and the data collected, each company has developed its own approach to ensure the safeguarding of all data, with a particular focus on protecting the data of minors.

Action 2024: Responsible gaming, with a focus on age classification and protection of minors' data. Strict data protection measures, including limited collection of personal data and compliance with global regulations. Adherence to age restrictions, ensuring games are rated according to international guidelines.

NesteFinland

We are committed to providing safe, high-quality products to our customers. Our approach to product safety and quality is governed by various policies and standards that ensure our products meet regulatory requirements and customer expectations.

We take a comprehensive approach to managing risks related to our own products throughout their lifecycle, including their use by consumers and end-users.

Novabase SGPSPortugal

Novabase Group adopts a structured approach in order to ensure protection of consumers and end-users, guaranteeing security, accessibility and the quality of the digital services rendered by Novabase. The Group has implemented wide-reaching policies regarding data ethics, privacy, cybersecurity, and business continuity, as proven by the certifications ISO/IEC 27001 (Information Security), ISO/IEC 27701 (Private Information) and ISO 22301 (Business Continuity).

In addition to the implemented policies, continuing vocational training and adoption of rigorous guidelines for developing and managing systems serve to reinforce Novabase's commitment to earning the trust and satisfaction of its consumers and end-users.

NovartisSwitzerland

Policies related to consumers and end-users

Patient-centered commitment

Our access policies are designed to ensure we do our part to address affordability, availability and equity in healthcare, while recognizing that meaningful progress requires collaboration across the entire healthcare ecosystem. Our commitment is guided by the belief that innovative medicines and healthcare solutions should be available to all who need them, regardless of geographic or economic barriers.

Product quality and safety

We prioritize quality and safety at each stage of a medicine's life cycle. During clinical trials and after launch, we monitor the use of our medicines to identify possible adverse events and minimize risks to patients. In the production phase, we ensure product quality from raw material sampling and testing to packaging, testing and distribution of finished goods.

Quality management system

To ensure product quality, we maintain a robust quality management system for our medicines in full compliance with requirements from health authorities and other regulators. We have licenses and relevant International Organization for Standardization (ISO) and Good Practice (GxP) certificates for all our activities, including clinical trials, manufacturing, medical devices, supply, warehouse and distribution operations.

Pharmacovigilance commitment

Pharmacovigilance involves monitoring the safety of medicines. Our approach to achieve effective pharmacovigilance relies on safety monitoring both during drug development and in the commercial setting, as well as the timely assessment and reporting of adverse events.

Falsified medicines combat

We also work to identify and combat falsified medicines, which can pose a serious threat to human health. Our efforts are focused on mitigating risks across three distinct areas: counterfeiting, theft and illegal diversion.

Novo NordiskDenmark

Patient access and protection

As the global prevalence of serious chronic diseases continues to increase, overburdened healthcare systems face growing pressure to deliver cost-effective, quality care, while millions of people lack access to essential treatments. In 2024, we reached more than 45.2 million people with our life-changing medicines – an increase of 3.6 million compared to 2023.

Access initiatives for vulnerable populations

As our business grows, so does our social responsibility to support vulnerable populations, and this year we were able to reach 8.4 million vulnerable people living with diabetes – a slight decrease compared to 2023.

Changing Diabetes® in Children programme

Key initiatives include Changing Diabetes® in Children (CDiC), which has reached over 64,000 children with type 1 diabetes in low- and middle-income countries since 2009. Support can include free life-saving medicine, blood glucose monitoring equipment and medical supplies for young people under 25.

Other access programmes

  • Partnering for Change: collaboration with the Danish Red Cross to address health issues in humanitarian crises
  • iCARE: integrated business model aimed at breaking down barriers to diabetes care in Middle Africa and Indonesia
  • Access to Insulin Commitment: providing access to affordable care for vulnerable populations
RocheSwitzerland

Consumers and End-Users Policies

Patient-Centric Approach: Our purpose is: doing now what patients need next. We believe it is urgent to deliver medical solutions right now – even as we develop innovations for the future. We are passionate about transforming patients' lives. We are courageous in both decision and action. And we believe that good business means a better world.

Access to Healthcare: Expanding access to healthcare is a core pillar of Roche's business strategy. Our approach involves identifying and addressing the root causes of access barriers at global, country and local levels. We collaborate with partners to create and deliver improvements to access tailored specifically to each country's healthcare environment.

Patient Safety and Quality: Personal safety of consumers and/or end users has been identified as one of our material subtopics. We are committed to ensuring the safety and efficacy of our products throughout their lifecycle.

Information and Privacy Protection: Roche is committed to collecting and using data in a lawful, fair, legitimate and ethical way and will always respect the privacy of individuals in order to earn and maintain their trust. Our navify digital solutions securely integrate data across care settings, connecting the healthcare community and accelerating access to innovation and insights.

Social Inclusion: Social inclusion of consumers and/or end users is identified as material. We are committed to ensuring our innovations are accessible to diverse patient populations and address health inequities.

UbisoftFrance

The Group has adopted monetization and engagement policies that respect the player experience and are sustainable in the long term. The golden rule when developing premium games is to allow players to enjoy the game in full without having to spend more. Monetization offers within premium games make the player experience more fun by allowing personalization of avatars or faster progress, however this is always optional.

S4-2

Processes for engaging with consumers and end-users about impacts

7 companies
DSBDenmark

Processes for engaging with consumers and end-users about impacts

Customer engagement through multiple channels DSB engages with customers through various mechanisms:

Commuter engagement In pursuing our business activities, DSB collaborates with various stakeholders, including our customers and local communities (for instance in the form of meetings with commuter clubs and an annual commuter rally).

Digital engagement platforms

  • DSB's app: Our largest sales channel with more than 1.8 million unique users, generating revenue to the tune of DKK 2.3 billion
  • DSB Plus loyalty programme: More than 1.8 million customers now have a profile, with more than 1.2 million having signed up for the bonus programme

Customer experience and feedback

  • We collect and implement valuable customer experience with a view to optimising operations management
  • Regular reputation tracking and customer satisfaction monitoring (DSB's reputation score of 72.9 in 2024, above the average of 70.1)

Service accessibility

  • It is still possible to buy tickets and other services at our stations, on our website and at our customer centres
  • Customer centres provide direct access for customer inquiries and feedback

Station experience DSB manages and develops almost 200 stations across Denmark. Customers should feel well guided at clean and secure stations. In the period to 2030, we are investing more than DKK 1 billion in station improvements.

Safety and security initiatives

  • We collaborate with the 'Natteravnene', a project that contributes to the sense of safety at the stations
  • Partnership with 'Livslinien' on focused efforts to prevent suicide on the railway

Traffic information and communication Traffic information supports operations management by providing frequent information to our employees and customers. Traffic information is collected and disseminated in close collaboration with Banedanmark.

Modern Times Group MTGUnknown

Our games engage passionate player communities across the world. Our studios actively nurture and engage these communities on different digital platforms. They focus on streamers and other content creators and manages both proprietary and public forums where players can engage with our brands and IPs.

NesteFinland

We actively engage with our customers through various channels to understand their needs and address any concerns about our products. This includes direct customer relationships, industry partnerships, and participation in sector initiatives.

We provide customers with comprehensive product information and support to ensure safe and appropriate use of our products.

Novabase SGPSPortugal

The company regularly monitors the satisfaction of its clients and that of its staff in relation to internal services and other topics of interest to management. These satisfaction surveys serve to collect feedback regarding the user experience, perceived risks and the potential impacts of the services rendered by the company.

NovartisSwitzerland

Processes for engaging with consumers and end-users about impacts

Patient support and education

We also support education programs for patients, providers and pharmacists, and provide regular training to employees in adverse-event reporting. For some medicines, post-approval studies may be conducted to collect more data on possible long-term adverse effects.

Clinical trial diversity

Diverse patient representation in clinical trials is critical to our R&D efforts. Understanding how patients from different demographic groups respond to treatment is essential to developing effective and inclusive medicines. To this end, we incorporate diversity principles into all Phase III studies with US participation, aligning with FDA guidance.

Our teams establish enrollment goals based on disease prevalence and demographic factors such as race ethnicity, sex and age to recruit a representative US population.

Pharmacovigilance reporting

Reports of adverse events from various sources — including clinical studies, literature and spontaneous reports — are used to evaluate and optimize risk management actions for the proper use of our medicines.

Global access strategies

For each new product launch, we work to address non-clinical barriers that may hinder adoption and uptake. By collaborating with governments and healthcare systems, we develop innovative pricing and access solutions tailored to the needs of individual markets.

Stakeholder collaboration

We work closely with payers to implement system-level mechanisms that align payments with measurable health outcomes, helping reduce ineffective spending.

RocheSwitzerland

Processes for Engaging with Consumers and End-Users

Patient Organisation Engagement: Roche engages with 1,292 patient organisations around the world to help strengthen healthcare systems. Our approach focuses on embedding the patient voice into every aspect of our disease area strategies internally, as well as on working alongside patient communities to drive meaningful change within healthcare systems externally.

Patient Benefits and Societal Impact Framework: This framework was co-created by Roche and patient organisations to systematically capture patient benefits and impact to society. The framework covers disease and treatment benefits, health-related quality of life improvements, patient pathway enhancements, financial impact reduction, patient empowerment, and societal impact.

Global Patient Think Tank: We established the Global Patient Think Tank (GPTT) – a dynamic, diverse coalition of patient community representatives – supporting the amplification of the patient community's voice within the global movement for UHC and driving on-the-ground implementation of the WHO resolution on social participation in health and well-being.

UHC Compass: Roche and the GPTT have co-created a UHC Compass, which aims to empower local patient leaders and communities to engage in appropriate discussions with the right health system stakeholders to advance UHC at the grassroots level.

Clinical Trial Engagement: We increased diverse representation in clinical trials as part of our health equity initiatives, ensuring patient voices are included in the development of our therapies.

UbisoftFrance

The Group has established direct relationships with consumers and end-users through digital transformation. Player communities are at the heart of the games and various engagement mechanisms are in place including community feedback systems and content creator programs.

S4-3

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

5 companies
Modern Times Group MTGUnknown

We want our gaming environments to be safe and respectful. To achieve this, our gaming companies have implemented policies, guidelines, and tools to address any unacceptable behavior.

NesteFinland

We have established customer service channels and complaint handling procedures to address any concerns or issues raised by consumers and end-users regarding our products.

Our customer engagement processes include mechanisms for receiving and responding to feedback about product quality, safety, and performance.

Novabase SGPSPortugal

Collection of feedback through client surveys is considered a first step toward correcting the negative impacts associated with the services rendered. After analysing the severity, Novabase implements the corrective measures appropriate to each situation.

NovartisSwitzerland

Processes to remediate negative impacts and channels for consumers and end-users

Pharmacovigilance system

Our pharmacovigilance systems are designed to comply with regulatory requirements for both individual case safety reports and periodic benefit-risk assessments. Reports of adverse events from various sources — including clinical studies, literature and spontaneous reports — are used to evaluate and optimize risk management actions for the proper use of our medicines.

This enables us to detect and manage pharmacovigilance risks that may emerge at any stage of a drug's life cycle. In accordance with international regulations, we share periodic safety reports with the relevant health authorities. We also perform regular benefit-risk analyses for our medicines to ensure their benefits continue to outweigh the risks.

Product recalls and remediation

We conduct thorough investigations whenever there is any evidence of deviation from quality standards, or if we detect failures in our processes. We take corrective and other measures where applicable, including proactively notifying health authorities.

Over the course of 2024, we experienced four recalls of nonconforming products, less than half the number in 2023. Of these, two were associated with moderate risk to patients (Class II recalls), though no patients experienced negative effects.

Quality remediation

Should we discover any gaps during audits, the audited entities are expected to resolve these through corrective and proactive actions (CAPAs). We monitor these and track adherence to the commitments to drive continuous improvement.

Falsified medicines response

We investigated every confirmed incident of falsified medicines reported to us — preventing falsified medicines from reaching and harming patients. We promptly notified local health authorities as required while also voluntarily reporting 100% of reportable incidents to the WHO within the recommended 10-day window.

UbisoftFrance

Reporting systems are systematically integrated into Ubisoft's online games to enable players to report issues so that they can be addressed quickly. The Group provides channels for consumers and end-users to raise concerns about their gaming experience.

S4-4

Taking action on material impacts on consumers and end-users

9 companies
LeonardoItaly

Consumer and End-User Impact Management

Global security solutions: Security has once again become a key issue on the agendas of many countries, and related investments increased, with the primary goal of protecting the building blocks of our society: people, institutions, natural resources, climate, territories, and infrastructure.

Multi-domain solutions: Leonardo has identified the issue as a priority both for the business and in terms of the materiality of its impacts, risks, and opportunities. The benefit of the solutions offered by the Group in the area of protecting territories, infrastructure and citizens, as well as in the area of emergency management, is recognised, even by stakeholders, as the most relevant impact generated by Leonardo on society.

Solutions portfolio: Solutions for security and progress in 150 countries - The solutions offered and developed by Leonardo include the most innovative global monitoring solutions, which, by integrating real-time data and information from multiple sources and multiple domains, and analysing it with AI algorithms, strengthen the ability to prevent, respond to, and manage any possible crises in increasingly complex scenarios.

Customer services: These include the gradual virtualisation of customer services that Leonardo has carried out in the aircraft field, through remote collaboration and online training that have reduced time and environmental impacts and increased the effectiveness and timeliness of customer support.

Modern Times Group MTGUnknown

We want everyone to be able to play and enjoy our games, including neurodivergent players. This is why our game studios are continuously developing and implementing different settings and mechanics which allow players with, for example, color blindness, visual impairments, or sensory sensitivity to play our games.

In promoting gaming for all, we also include the significance of maintaining a healthy balance between engaging with our games and life outside of our games, particularly for our younger players.

NesteFinland

We continuously work to improve our products and services based on customer feedback and changing market needs. Our innovation and R&D efforts focus on developing solutions that meet customer requirements while advancing sustainability goals.

We monitor product performance and customer satisfaction to identify opportunities for improvement and ensure our products continue to meet quality and safety standards.

Novabase SGPSPortugal

Novabase has implemented a pro-active approach for mitigating risks and maximizing opportunities associated with the services it provides. In order to reduce negative impacts, the Group has adopted rigorous privacy and security policies, ensuring data protection and compliance with regulations via internal and external audits, the latter conducted by certifier entities.

NovartisSwitzerland

Taking action on material impacts on consumers and end-users

Research and development for unmet needs

We systematically assess our R&D portfolio against unmet medical needs, integrating access considerations early in the development process. By the end of Phase II, we anticipate potential access barriers and enablers to ensure our investigational medicines have the potential to reach patients that could benefit the most.

Innovation and technology advancement

Novartis is working to transform its pharmacovigilance system, using technologies such as artificial intelligence to simplify processes and generate new safety insights for health authorities, healthcare providers and patients.

Global access implementation

We implement global access strategies for all new medicines launched. For example, our global access strategy for Fabhalta explores ways to partner with healthcare systems to expand access to this novel treatment for patients with paroxysmal nocturnal hemoglobinuria.

In 2024, we received 20 approvals in the US, EU, Japan and China, including US approval for Fabhalta (iptacopan) to treat adults with immunoglobulin A nephropathy (IgAN), a progressive, rare kidney disease in which the immune system attacks the kidneys.

Supply chain security

We have strengthened our supply chain security capabilities and governance to improve our ability to mitigate incidents of product theft in high-risk regions.

Product authentication

In 2024, we significantly increased the number of countries in which Authentifield devices are deployed and activated to 69, expanding our timely field product authentication capabilities from packaging (MoVE) to drug product (Authentifield).

Quality management

We successfully completed our first ISO 9001:2015 surveillance audit in 2024 without any nonconformities. In 2024, health authorities including the EMA, Swissmedic and FDA carried out a total of 124 inspections of Novartis clinical and manufacturing operations. All the health authority inspections were deemed acceptable, compared with 99.1% in 2023.

RocheSwitzerland

Taking Action on Consumers and End-Users

Healthcare Access Initiatives: In 2024, we continued to work with partners both locally and globally to provide sustainable patient access to quality and affordable healthcare. Key initiatives include:

  • EMPOWER Kenya: screening over 132,000 women for cervical and breast cancer, with EMPOWER 2.0 launched to screen 300,000+ women
  • Pre-eclampsia screening in 18 public hospitals and 14 private institutions across Argentina, Bolivia, Paraguay and Uruguay
  • African Breast Cancer Ambition: improving five-year survival rates for African women with breast cancer to 80%
  • City Cancer Challenge partnership reaching an estimated 66.5 million people across 15 cities

Patient Safety Measures: We implement comprehensive measures to ensure personal safety of consumers and end users throughout our product development and commercialisation processes.

Digital Health Solutions: Our navify digital solutions securely integrate data across care settings, connecting the healthcare community and accelerating access to innovation and insights. We have introduced AI-powered predictive algorithms in solutions like the Accu-Chek SmartGuide for diabetes management.

Privacy Protection: Not being able to use data generated by Roche because of privacy reasons leads to decreased revenue due to the loss of new business segments or a slower product innovation process. We manage this risk through robust data protection measures and ethical data use practices.

Health Equity Actions: We work to double the number of patients receiving our core pharmaceutical therapies in low- and lower-middle-income countries (LLMICs) by 2026 and increased diverse representation in clinical trials.

Royal SchipholNetherlands

Airports' attractiveness to consumers and end-users

Passenger Experience Score: 3.78 Target 2024: 3.96; result 2023: 3.79

In 2024, we changed from a Net Promoter Score (2023: +36) to the average Passenger Experience Score, which declined slightly by -0.01 compared to 2023, reaching a 12-month rolling average of 3.78. While overall performance remained largely stable, there were differences between the three journeys. The Departure Journey saw a slight decrease of -0.01, reaching 3.81. This was primarily influenced by the topic 'Cleanliness of the airport'. The Transfer Journey experienced a decline of -0.07, dropping to 3.98, influenced by the topics 'State of maintenance of the airport' and 'Cleanliness of the airport'. The Arrival Journey was the only journey to show improvement, increasing by 0.04 to 3.62. This growth was driven by improvements in terms of 'Waiting time at passport control' and 'Ease of finding your way'. Despite these developments, the annual target was not met. The focus remains on improving specific touchpoints to further enhance passenger satisfaction in 2025.

Investment in passenger experience

In recent years, overall passenger satisfaction for Schiphol has declined. According to ACI's Airport Service Quality benchmark, passengers rated Schiphol the lowest of eight major European hub airports. The other seven are Paris Charles de Gaulle, Copenhagen, London Heathrow, Madrid, Munich, Istanbul and Zurich. In 2023, the benchmark once more put Schiphol in last place, indicating that despite efforts to improve the airport, the passenger experience is not yet at the level it should be.

In 2024, Schiphol announced that between 2024 and 2029, it will invest 6 billion euros to improve the airport facilities. Important aspects of the airport infrastructure—including Pier C, the baggage basement, climate control systems, escalators, aircraft stands and taxiways—are due for major maintenance or renewal. Pier A will be completed and new construction projects, such as the new baggage basement, will begin.

Network connectivity

TPI Network – Intercontinental destinations: 124 Target 2024: 125; result 2023: 126

The number of direct intercontinental destinations for passengers and cargo. In 2024, the TPI Network was 124 intercontinental destinations, which is one below the set target for the year and two fewer than in 2023. We welcomed six new destinations, while eight destinations were discontinued, resulting in a net loss of two destinations in 2024. Of the 124 destinations, 19 are cargo-only destinations.

Even though we did not reach our target in 2024, Schiphol has maintained its status as the second best connected airport in terms of direct connectivity, placing behind Istanbul but ahead of London Heathrow, Paris Charles de Gaulle and Frankfurt. This is according to the Airport Industry Connectivity Report 2024 by ACI Europe.

Passenger and traffic volumes

Total passengers RSG: 75,881,197 (2023: 70,946,209) Air transport movements RSG: 529,248 (2023: 498,194) Cargo: 1.49 million tonnes (2023: 1.38)

In 2024, 66.8 million passengers flew to, from or via Schiphol, an increase of 8% compared to 2023. The number of flights to and from Schiphol was 473,815, an increase of 7% compared to 2023.

TrygDenmark

Customer satisfaction initiatives: Tryg achieved a customer satisfaction level of 87 in 2024, an improvement of 3 percentage points since 2020, but slightly below the 2024 target of 88. Customer satisfaction remains paramount to Tryg, and the company continues to work diligently to meet and exceed customer expectations.

Technology solutions for customer experience: During 2024, Tryg launched new technology solutions to enhance the customer experience:

  • In Denmark, the AI assistant Felix offers tailored suggestions and input to customer advisors in real time
  • In Norway, AI and advanced voice analytics are used to train and coach customer advisors
  • In Sweden, the AI assistant Llucia offers faster response to customers with child insurance policies

Customer service improvements: By leveraging advanced speech analytics applied to dialogues between advisers and customers, Tryg has been able to provide tailored training and coaching. As a result, nearly 60% of advisors have improved their customer satisfaction scores and 40% have boosted sales. This earned Tryg two prestigious national awards: first place in the national response time championship and the Customer Service Award in the insurance category.

Product adaptations: Tryg has redesigned several products to better serve customers:

  • Child insurance with deeper focus on supporting mental health
  • Motor insurance products ranked as best on the market according to Swedish Consumers' Insurance Bureau
  • Digital payment solutions through Swish enabling instant claim compensation
  • Partnership with LEIA Health to support new parents

Prevention initiatives: Cooperation with SMHI enables Trygg-Hansa to warn clients in areas at risk of storms and share preparation tips. AI features warn clients in specific areas where increased claim frequency is identified.

UbisoftFrance

The Group takes action on material impacts on consumers and end-users through initiatives such as the global player Code of Conduct, 'Fair Play' awareness program, private reputation scoring in Tom Clancy's Rainbow Six® Siege, and the 'Good Game Playbook' to promote better mental health online. Since September 2024, children aged 7 and over can create Ubisoft accounts with age-appropriate protection settings.

S4-5

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

3 companies
Novabase SGPSPortugal

No specific targets have been set for 2024 as of yet. The Group continues to assess its initiatives and respective results, taking into account the policies implemented at Novabase.

NovartisSwitzerland

Targets related to managing material impacts on consumers and end-users

Access to medicines targets

Access Target202420232022Progress
Implement a global access strategy for all new medicines launched (%)100100100Achieved as annual target

Patient reach metrics

Patient Impact Metric202420232022
Patients reached (millions)296284267

Innovation and approval targets

Innovation Metric202420232022
Submissions (US, EU, Japan, China)291824
Approvals (US, EU, Japan, China)202223
New molecular entity (NME) approvals011

Product quality and safety targets

Quality Metric202420232022
Total recalls4107
Class I recalls010
Class II recalls286

Key achievements in 2024

  • Maintained 100% implementation of global access strategies for all new medicine launches
  • Reached 296 million patients worldwide with our medicines
  • Reduced product recalls by more than half compared to 2023
  • All health authority inspections were deemed acceptable (100%)
  • Maintained voluntary reporting of 100% of falsified medicine incidents to WHO within recommended timeframes
TrygDenmark

Tryg has set strategic targets related to customer satisfaction and service excellence:

Customer satisfaction target 2027: For the new strategy period, Tryg has set a customer satisfaction score target of 83 by 2027. Tryg has rebased the customer satisfaction baseline from 87 to 81 due to updated scoring methodology and inclusion of the entire Swedish business.

Straight-through processing target: Tryg aims to increase straight-through processing for digitally reported claims to over 55%, an improvement of 10 percentage points from the baseline of 45%. This target focuses on fast and efficient claims handling through automated processes without manual touchpoints.

Value-creating actions target achieved: Tryg set a target to grow 'value-creating actions' upon logging in online by 40% or above. The company boosted 'value-creating actions' by more than 50% during the strategy period through initiatives like 'My Page'.

Tryg believes that high customer satisfaction and retention rates contribute to lower distribution costs, making the achievement of customer satisfaction targets crucial for realising financial objectives.