
Annual Report 2025 STATUTORY REPORTING ON CORPORATE GOVERNANCE 6
STATUTORY REPORTING ON CORPORATE GOVERNANCE
CORPORATE SOCIAL RESPONSIBILITY
Danske Commodities’ commitment to ethical standards
and corporate social responsibility is a focus area in the
Group’s activities.
Danske Commodities conducts its business consistently
with the Corporate Social Responsibility Directive and
supports the Paris Agreement and a net-zero future. Fo-
cusing particularly on advancing the Sustainable Devel-
opment Goal (SDG) 7, Danske Commodities’ business
model is guided by the energy transition, and the Group
wishes to play an active role in the expansion of a re-
newables-driven energy system. Danske Commodities
believes that real value lies in the work carried out by
its people, anchored by four main sustainability themes:
ethics, equality, people and planet.
THE GROUP’S MAIN ACTIVITY
Danske Commodities is a tech-driven energy trading
company that trades power and gas on a global scale.
The Group’s trading activities cover time-delimited mar-
kets from forward to day-ahead and intraday. Using
comprehensive data sets, analytical capabilities, auto-
mation and deep market knowledge, Danske Commodi-
ties brings renewables to the market, provides flexibil-
ity, helps create balance and ensures that energy flows
smoothly to meet changing demands. Every day, the
Group uses its market expertise, broad market footprint
and 24-hour trading setup to connect energy producers
and large-scale consumers to wholesale markets
through tailor-made services.
ETHICS
POLICY
At Danske Commodities, ethics and compliance are not
just priorities – they are foundational to how we oper-
ate. We are committed to conducting business with in-
tegrity, transparency, and responsibility, recognising
that this is not only the right way to work, but the only
way to work. This commitment is embedded in our Com-
pliance Programme and Code of Conduct, which to-
gether form the backbone of our ethical framework.
HOW THE POLICIES ARE PUT INTO ACTION
Compliance in practice
At Danske Commodities, our compliance programmes
translates policy into practice through clear expecta-
tions, structured processes, and ongoing support. It en-
sures that all employees understand their responsibili-
ties and act in accordance with applicable laws, inter-
nal standards, and ethical principles. This includes em-
bedding compliance into daily operations, providing ac-
cessible guidance and enabling proactive risk manage-
ment. Regular reviews, cross-functional collaboration
and transparent communication help ensure that com-
pliance is not just a requirement – but a shared respon-
sibility across the organisation.
Training and awareness
Danske Commodities values and invests in targeted
compliance training to build awareness and foster ac-
countability. Programmes are tailored to business needs
and include annual refreshers and onboarding sessions,
helping employees navigate complex regulatory re-
quirements with confidence.
Anti-Bribery & Corruption (‘ABC’)
Danske Commodities maintains a zero-tolerance ap-
proach to bribery and corruption. Our Anti-Bribery and
Corruption (ABC) programme sets out clear policies,
procedures and standards designed to prevent unethical
behaviour across our operations. The programme en-
hances organisational awareness through targeted
training and communication and ensures that controls
are implemented, monitored and continuously improved.
It is structured around four key pillars – prevention, de-
tection, response and oversight – which collectively
support an effective compliance framework and help
ensure alignment with regulatory expectations and
best-practice standards.
Speak up culture
Danske Commodities encourages a culture of openness
and integrity. Through our whistleblower scheme, em-
ployees and third parties can raise concerns confiden-
tially and without fear of retaliation. The initiative –
known as “Speak up, reach out” – is supported by inter-
nal reporting channels and an Ethics Helpline, which
also allows for anonymous disclosures. This ensures
that anyone connected to our business can report uneth-
ical behaviour safely and responsibly.
RISKS
Non-compliance with applicable laws and regulations
can expose Danske Commodities to significant conse-
quences, including legal liability, financial losses, regu-
latory sanctions, reputational harm and adverse effects
on individual employees or teams.
RESULTS IN 2025
Reviewed, enhanced and implemented compli-
ance programmes relating to Anti-Bribery &
Corruption & Human Rights (‘ABC’), and Anti-
Money Laundering & Sanctions (‘AML’). This in-
cluded updating policies and documentation,
strengthening organisational awareness and
refreshing all related training materials to en-
sure clarity, alignment and effectiveness.
Successfully implemented a new Learning Man-
agement System (LMS) to support continuous
learning and compliance development. The LMS
rollout expanded training offerings, enabled
targeted and role-specific learning journeys
and improved tracking of employee training
progress and development needs.
Established guidance and governance for the
responsible and compliant use of AI, ensuring
alignment with the EU AI Act. Focus placed on
enabling the organisation to leverage AI’s ca-
pabilities ethically and securely, while manag-
ing associated risks and maintaining transpar-
ency and accountability.