Responsible tax

Human rights

A.P. Moller - Maersk (Maersk) is committed to respecting human rights, in line with the UN Guiding Principles on Business and Human Rights (UNGPs). As members of the UN Global Compact since 2009, we have been integrating our commitment since and reporting our progress on our website and in sustainability reporting.

Human rights are managed across many different business areas (see overview below) and governed through the central governance framework, Commit. In addition, human rights as a cross-cutting topic is governed via our ESG governance framework (see p. 12). We engage regularly with stakeholders, including rightsholders, on how we manage our human rights responsibilities.

Preparing for mandatory requirements

In 2021, we formalised our commitment to respect human rights by publishing Maersk's Human Rights Policy statement on the sustainability website on Maersk.com. The statement complements existing commitments to respect human rights as outlined in our Employee and Supplier Codes of Conduct. We have also firmly anchored the topic of human rights in the new ESG governance framework, ensuring human rights risk assessments are conducted regularly and issues can be escalated when relevant.

These measures serve to strengthen our human rights programme and prepare Maersk for continued compliance with increasing regulatory measures based on the UN Guiding Principles, and documentation requirements brought about by the implementation of EU regulations on sustainable finance, corporate reporting and mandatory due diligence in value chains.

Re-determining our most salient risks

In 2021, we performed a corporate-level human rights assessment with a third-party provider, reviewing our business operations and relationships to refresh our understanding of our potential and actual human rights risks and impacts across the company’s value chain. We consider this an important step at a time when Maersk’s evolution to an integrated transport & logistics company is also transforming our human rights risk profile.

The issues identified as most salient across our value chain are health & safety, working conditions (wages, benefits and hours), modern slavery and access to remedy. In addition, there are emerging issues linked to data ethics and just transition. In 2022, we will define and prioritise areas for action. Some of these activities will include continued efforts to improve due diligence on high-risk suppliers and strengthening our grievance mechanisms.

Integrating human rights in due diligence processes

In 2021, we continued to integrate human rights issues into existing due diligence processes. Some of these efforts included: • Incorporating questions on community impacts in our environmental screening of

M&A opportunities. • Strengthening or efforts to capture human rights relevant risks in third-party due diligence.

For 2022, we will continue this progress, using the recommendations from the corporatelevel human rights assessment as a guide, and communicate developments on our website.

Human rights in this report

Climate change p. 27 The right to life, the right to work and the right to adequate standard of living.

Diversity, equity and

inclusion p. 40 The right to freedom from discrimination and the right to family life. Air emissions p. 31 The right to the highest attainable standard of health.

Employee relations p. 42 Human rights principles and standards related to labour, for example freedom of association and collective bargaining, equal treatment, child labour, forced labour, working hours, compensation, privacy, rest and leisure. Responsible ship recycling p. 33 Human rights principles and standards related to labour, in particular the right to life and the right to the highest attainable standard of health.

Data ethics p. 48 The right to privacy, the right to freedom from discrimination and the right to freedom of expression. Safety and security p. 36 The right to life and the right to the highest attainable standard of health.

Sustainable procurement p. 46 Human rights principles and standards related to labour. Why it matters

Many aspects of our business touch on human rights, including our employees' working conditions, health and safety, how our vessels are built, how we use digital data and technologies, and our suppliers' business practices. Our conduct within our own business and through our business relationships can therefore have a significant impact on society, both positive and negative. Further, increasing regulation and growing expectations from our stakeholders confirm that human rights is a material topic for Maersk.

Ambition

Continue aligning our business practices with the UN Guiding Principles, and ensure that human rights considerations are integrated into our due diligence processes and ESG governance mechanisms.

8.5 8.7 8.8 16.3

Targets

2022

• Develop action plans addressing the salient human rights risks identified in the human rights assessment • Formalise Maersk's human rights governance framework