Governance

We have identified the source of an estimated 90% of our emissions. We continue to focus on identifying the remaining emissions, and we are working to ensure that as much as possible is 'activity based'. Our suppliers are also on hand to help ensure that the correct data is obtained.

We require our suppliers to respect human rights and principles regarding, among other things, health and safety, discrimination, privacy, data security, and fair working conditions. These requirements are included in our partnership agreements. We also reserve the right to conduct inspections of suppliers whose employees work at our hotels on a daily basis.

We work with suppliers and conduct business in Denmark and Sweden. Although the risk of corruption and bribery is considered low, it is an important area to focus on. That is why we have developed an anti-corruption policy that applies to both permanent employees and temporary staff, so that it is clear to all employees which guidelines apply.

Part of Comwell’s core values is that we keep our word—and this applies to all aspects of our business. That is why we naturally comply with all applicable laws governing business operations in Denmark. We also adhere to the collective bargaining agreements we have signed, as well as the mandatory whistleblower program, which is, of course, important to us. The whistleblower program should be viewed as a supplement to the mechanisms we already have in place at Comwell, where we have established a confidential forum involving both the organization’s leaders and the HR department.

Furthermore, our ESG report and Communication Progress are also part of how we ensure compliance with the issues we address. Therefore, our reporting is conducted in accordance with applicable regulations and includes our ESG objectives.

In order to maintain the trust that guests, employees and business partners have in Comwell, we have drawn up a number of data ethical principles that support our desire to create openness about Comwell's data use and supplement our principles of transparency and data minimisation in the data protection rules.

Therefore, we only collect personal data that is relevant and in accordance with applicable legislation. Among other things in connection with contact information and purchase history with guests and business partners and in connection with Comwell Club enrolment. Comwell Club enrolment, but also many other important parameters.

Our data ethics principles are based on recommendations from the Data Ethics Council.

The processing and use of data at Comwell must be conducted in a responsible, transparent, and reliable manner, with respect for privacy and without discrimination.

We prioritize security when storing and sharing data and take measures to protect data from accidental or unauthorized access.

Employees, guests, and business partners may request access to their own personal data in accordance with applicable data protection regulations.

All employees at Comwell Hotels must process personal data in accordance with Comwell’s privacy policy, data protection regulations, and the rules regarding professional secrecy and confidentiality.

Comwell does not sell personal data to third parties.

Potential impacts on our business are expected to arise, among other things, in connection with stricter requirements and legislation aimed at reducing the climate impact of our operations, including requirements for waste sorting by category. At the same time, there is a strong focus on the green agenda in the kitchen, as well as on responsible procurement with an emphasis on resource-saving solutions and minimizing waste in both the production and service phases.

The most important resource at Comwell is our employees, and changes in the labor supply have a major impact on our industry as a whole. A decline in the number of new trainees and challenges in finding qualified workers are factors we are actively addressing in an industry characterized by shifting work schedules and physically demanding work. In this context, our ability to reflect and promote diversity and inclusion is essential to ensuring that we can continue to grow our business and attract the right talent in the future.

We monitor developments so that we can continuously adapt our hotel operations with a focus on, among other things, energy consumption, resource use, recycling, and waste sorting. In 2026, Comwell’s greenhouse gas emission reduction targets were validated by SBTi Services in accordance with the relevant criteria from the Science Based Targets initiative. The validation applies to the reduction targets—not to our specific plans, initiatives, or progress toward the targets.

Our ingredients policy includes procedures focused on more plant-based dishes, efficient use of ingredients, and reduced food waste. All of our Danish hotels have been awarded the Bronze Organic Dining Label, and whenever possible, we prioritize seasonal Danish ingredients. This work is supported by employee training, including the Green Chef program, as well as quality checks at our suppliers.

Employee development and well-being are integral to Comwell’s business strategy. We strive to create an environment that takes into account that employees may be at different stages in their careers and professional lives. Through training programs at Comwell College and our Trainee Academy, we give employees the opportunity to develop both professionally and personally.

We monitor employee well-being through ongoing well-being surveys. We also work to achieve a more balanced gender distribution on the board of directors and in senior management, and to support employees at different stages of life, including through our late-career policy.