Fair Pay & Worker Respect

In 2024, the CEO's total remuneration was DKK 57.1 million, while the average employee remuneration for the parent company was DKK 1.02 million, resulting in a CEO to median employee pay ratio of approximately 56:1.

Regarding pay equity, women are paid 3% more than men across job descriptions and geographical locations, according to Deloitte LLP data cited in June 2025.

Fair Trade & Ethical Sourcing

Novo Nordisk conducts annual audits for high-risk suppliers.

No child labor or forced labor concerns were reported to the Compliance Hotline or observed during internal Business Ethics Reviews and EHS audits in 2023, and proactive risk assessments are ongoing. The Responsible Sourcing program covers all global Tier 1 suppliers, and Tier 1 suppliers are asked to uphold similar standards for their own suppliers, but less than 5% of suppliers are mapped beyond Tier 1. Corrective action plans for violations are typically agreed upon within 30 days, with the supplier initiating and implementing actions within the agreed timeframe. The company's Responsible Sourcing Standards, which include ethical terms, are expected to be complied with by all suppliers, and contractual agreements with all third-party representatives include mandatory ethics and compliance clauses. Suppliers are risk-assessed for business ethics issues, and the company requires due diligence on critical raw materials and conflict minerals.

Honest & Fair Business

Novo Nordisk Inc. incurred a $6.3 million fine in 2022 for False Claims Act violations.

The company published a voluntary admission in 2024 of failing to disclose £7.8 million in payments between 2020 and 2022, which constitutes one restatement in three years. The company was under an audit cycle in March 2023 due to its suspension from the ABPI, and a re-audit is expected in October 2024 to evaluate disclosure processes. The Audit Committee oversees the internal audit function, but no specific percentage of audit coverage is provided. Novo Nordisk was suspended from the ABPI in 2023 for two years and breached 16 clauses of the ABPI’s Code of Practice, bringing discredit to the industry. The company has a Compliance Hotline for reporting misconduct, with protection against retaliation and identity protection, and reports are acknowledged within 7 days, with feedback generally provided within 3 months. The Board of Directors consists of nine members, with two of the five shareholder-elected members considered independent, meaning 22% of the total board is independent. The company has a comprehensive anti-corruption policy that prohibits bribery, facilitation payments, and fraud, and commits to complying with international anti-corruption laws.

Kind to Animals

Novo Nordisk is not cruelty-free due to pre-clinical animal testing, meaning no products are certified cruelty-free.

The company develops and uses alternative methods like computer simulations, tissue cultures, and cell-based methods, particularly in early drug discovery and for batch quality control. They are working to phase out the use of products from horseshoe crab species for safety testing, with most testing expected to end by 2027 and full discontinuation targeted for 2025-2035, pending regulatory approval. The Bioethics policy follows the 3R principles (Replace, Reduce, Refine), sets standards for animal housing, care, transport, and health monitoring, and requires the Ethical Review Council to review all studies involving animals. The company monitors and audits external partners, contract research organizations, and suppliers for ethical and welfare standards, with 20% of animal studies performed by external contractors. In 2025, 46,869 animals were purchased for research, a 5% decrease from 2024, with 96% being rodents. However, the use of dogs and non-human primates increased in 2025 due to late-stage research projects. In 2023, 807 primates were used, an increase from 168 in 2019. The company contributes 300,000 DKK annually for three years (starting 2014) to the 3R Centre and is establishing a dedicated unit to accelerate animal-free methods. Novo Nordisk participates in initiatives like The Danish 3R-Center, EPAA, and IVTIP, and collaborates with industry partners and animal welfare groups to develop alternatives. They engage with governments, regulators, and animal welfare groups to advocate for animal welfare and improved standards, and publicly endorses specific animal welfare reforms. The company acknowledges that its operations impact local ecosystems and has plans to develop a plan by the end of 2025 to restore areas of nature, develop a global restoration plan by 2026 to achieve nature positive status by 2045, and restore biodiversity at priority sites by 2033.

No War, No Weapons

Novo Nordisk's Business Ethics Code of Conduct and Responsible Sourcing Standard both emphasize compliance with the UN Guiding Principles on Business and Human Rights.

The Responsible Sourcing Standard requires suppliers to address conflict minerals, with 45% of materials verified conflict-free.

Planet-Friendly Business

Novo Nordisk reported total Scope 1, 2, and 3 emissions of 2.261 million tCO2e in 2024, which increased by 23% compared to 2023.

The company has a net-zero emissions target for 2045, with Scope 1 and 2 emissions targeted for zero by 2030, and a 33% absolute reduction in Scope 3 emissions by 2033 from a 2024 baseline. These targets are SBTi-validated, with the Scope 3 target aligned with a well below 2.0°C pathway and the net-zero target aligned with the Corporate Net-Zero Standard. In 2024, 77% of total energy consumption was from renewable sources, and 100% of electricity at production sites was renewable. Approximately 23% of total water withdrawal occurs in areas with high or extremely high water stress. The company achieved an 85% waste diversion rate in 2024, with a target of zero landfill waste from production sites by 2030. In 2024, 6% of capital expenditure was aligned with the EU Sustainable Taxonomy. The company uses Life Cycle Assessment (LCA) methodology for products and conducts annual environmental assessments at all production sites, reporting zero failed environmental inspections in 2024. Novo Nordisk aims for a 30% reduction in plastic footprint per patient by 2033 compared to 2024, with a 2024 plastic footprint of 0.35 kg per patient. The company aims to halt nature loss in its value chain by 2033 and be nature positive by 2045. More than 1,800 suppliers have committed to transitioning to renewable electricity, and the company expects suppliers to set science-based targets. Climate-related risks are identified and assessed, including high-level assessments of physical and transition risks considering 4°C and 1.5°C scenarios. No aspects of the business were identified as incompatible with a transition to a climate-neutral economy.

Respect for Cultures & Communities

Novo Nordisk reported that 99% of its employees completed human rights training in 2023, and again in 2024, which included human rights components.

No other specific, quantitative data points were found for the remaining KPIs related to Respect for Cultures & Communities.

Safe & Smart Tech

Novo Nordisk has adopted data and AI ethics principles, is expanding its global data protection program to cover AI ethics, and is establishing proper governance for AI systems.

This includes strategies for unintended negative consequences, continual monitoring, human control, oversight, and accountability for AI use throughout its lifecycle. The company provides annual or ad hoc training on personal data protection, including Binding Corporate Rules, and conducts mandatory e-learning for all employees on ethics and compliance. It implements appropriate technical and organizational measures to protect personal data, including encryption, and uses pseudonymization and anonymization where relevant. The company is building an AI Ethics & Compliance framework that incorporates risk assessments and mentions impact assessments and audits in its policy. It aims for transparency in AI use, describing when and how AI is used, how personal data is utilized, and the goals, data, and limitations of AI systems. Novo Nordisk offers users control over cookie preferences and outlines data subject rights including access, rectification, erasure, and data portability. It has a Coordinated Vulnerability Disclosure (CVD) Policy, acknowledging reports within five business days and providing recognition for verified vulnerabilities. The company's cybersecurity risk management program is validated through peer-benchmarked maturity assessments, external technical assessments of core infrastructure, key applications, and operational processes, as well as group internal audit evaluations. Novo Nordisk outlines data minimization and storage limitation principles, retaining personal information only as reasonably necessary. However, the company was found guilty of multiple compliance failures by the PMCPA, including breaching the ABPI Code of Practice's Clause 2, leading to its suspension from the ABPI in 2023 due to undisclosed and misattributed payments. The company has processes to identify, assess, and mitigate risks of discrimination and bias in AI, including continuous monitoring and adaptation. Novo Nordisk states that AI systems should be designed and utilized to respect the rights and dignity of all people.

Zero Waste & Sustainable Products

In 2024, Novo Nordisk achieved an 85% waste diversion rate, with 15% of total waste directed to disposal and 85% recycled, recovered, or prepared for reuse.

The company also reduced the total volume of production waste directed to landfill by 92% compared to its 2019 baseline. However, it conservatively assumes zero recyclable content in its products due to a lack of established recycling infrastructure for pharmaceutical waste. A conservative estimate for recyclable content in product packaging is 28%. The ReMed™ device take-back scheme is active in seven key markets, covering approximately 20% of injection pens supplied, and has seen over four million pens returned. Circular design guidelines are applied to every design process, considering expected lifetime, sustainable materials, waste reduction in production, and recyclability. The company has a global target of zero landfill from production sites by 2030 and aims for a 30% reduction in plastic use per patient by 2033. Hazardous waste accounted for 23% of total waste, with equal splits between recycling/recovery and disposal via incineration. Pre-filled devices have a durability of 24-36 months, while reusable devices last 60 months, which is at the higher end of the industry range. The company had no waste disposal violations in the past three years. It has waste requirements for all tier-1 suppliers, including commitments to renewable energy. Novo Nordisk educates customers on the ReMed™ scheme to increase return rates and recycled volumes.