ESG policy

Purpose and scope

Level Consulting A/S (“Level” or “we”) is a Nordic commercial and technology consultancy. We are based in Copenhagen, operate across the Nordics, and deliver consultancy services to clients in many industries, including insurance, pension, energy, telecom, media and manufacturing. Many of our clients prepare sustainability reports under the Corporate Sustainability Reporting Directive (“CSRD”), and many operate under the General Data Protection Regulation (“GDPR”) and the Digital Operational Resilience Act (“DORA”). This policy sets out how Level takes responsibility for its own impact while supporting our clients in meeting their obligations.

The policy applies to Level, all employees and the work we deliver for clients. We keep it proportionate to Level’s size, and it only describes practices we actually follow.

Our footprint

As a knowledge-work business with one office in Copenhagen, our direct environmental footprint is small. Our main impacts are:

• Energy for heating and electricity in our office
• Business travel in Denmark, across the Nordics and in Europe
• Digital infrastructure: the cloud platforms and tools we use and set up for clients
• Consumption in the office, including food and single-use items

Our biggest responsibility lies in how we handle our clients’ data and systems. That is why governance and data protection carry the most weight in this policy.

Environment

We focus on practical everyday measures that fit a company of our size:

• Travel: We follow a travel guideline that keeps air travel to a minimum. Where possible, we meet online rather than travel to meet in person, and we encourage employees to cycle or use public transport to work.
• Energy: We switch off lights and equipment when we leave a room or the office. We track the office’s annual consumption of district heating and electricity.
• Waste and consumption: Employees are encouraged to take surplus lunch home to reduce food waste. We have installed sparkling-water dispensers to cut out bottles and cans, and we sort our waste for recycling.
• Ways of working: We encourage walk-and-talk meetings as an alternative to sitting in a meeting room.

We have not set formal emission reduction targets, and we do not currently calculate a full carbon footprint.

People

Our people are our business, and we treat them with fairness and respect.

• Working conditions: Our employee handbook sets out employment terms, working conditions, health and safety, and expected conduct. All employees have access to it.
• Equal pay and non-discrimination: Women and men in comparable roles, including management roles, are paid at the same salary level. We do not accept discrimination or harassment of any kind.
• Speaking up: Employees can raise concerns anonymously through an internal HR channel. This covers harassment and discrimination, employment matters, health and safety, human rights, and client data and privacy.
• Development: Every employee has a fixed number of hours each year set aside for personal and professional development.
• Wellbeing: We value a healthy, active workplace, and we encourage movement during the working day.

Governance and business ethics

Our clients trust us with customer data and business-critical systems. We protect that trust through documented controls that are tested regularly and checked independently.

• Data protection: We have a data processing agreement in place with every client where we process personal data on the client’s behalf, and we audit our GDPR compliance regularly. Our privacy notice describes how we process personal data as data controller.
• Independent assurance: Level obtains an ISAE 3000 (GDPR) audit statement in its capacity as data processor. The latest audit report is available by contacting our DPO at dpo@levelconsulting.com.
• Information security: Our information security policy sets the rules for access, devices, handling of client data, and incident response.
• Operational resilience: Many of our clients are financial entities under DORA, and Level is one of their ICT third-party service providers. We work with them on the requirements DORA places on providers, including security, incident reporting, audit rights and exit arrangements.
• Anti-corruption: We do not offer, give or accept bribes, kickbacks or improper gifts or hospitality. We compete on the quality of our work.
• Integrity in advice: We give independent advice. If a commercial interest could affect a recommendation, we tell the client.

Suppliers and partners

Our supply chain is short. It consists mainly of software platforms, cloud services, office services and occasional subcontractors.

• We use established platform vendors whose security and data protection terms meet our clients’ requirements.
• Level enters into data processing agreements with all sub-processors that handle client personal data, in accordance with the GDPR.
• We accept and follow our clients’ supplier codes of conduct as part of our engagements.

Supporting our clients’ CSRD reporting

Level is not itself required to report under the CSRD. Many of our clients are, and we are part of their value chain.

When clients ask for sustainability information about us, we provide it openly and consistently with this policy. We answer through the channels they use, such as supplier questionnaires and sustainability platforms. Our answers follow the scope EU rules set for smaller value-chain partners, which is based on the voluntary SME standard (VSME).

Ownership and review

Our Managing Partner, Søren Brahm Lauritsen, is responsible for ESG matters at Level, including this policy and our answers to client sustainability requests.

Management reviews this policy at least once a year and updates it when our business or the regulation changes. If you have any questions about this policy, please contact sl@levelconsulting.com.

This policy was last updated on 20 October 2026.